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Witness name: Benjamin Andrew Foat
Statement No.: 0100
Dated 23 March 2023
THE Post OFFICE HORIZON IT INQUIRY
WITNESS STATEMENT OF BENJAMIN ANDREW FOAT ON BEHALF OF Post OFFICE LIMITED
IN THE Post OFFICE HORIZON IT INQUIRY
1. 1, Benjamin Andrew Foat of Finsbury Dials, 20 Finsbury St, London EC2Y 9AQ, am
Group General Counsel of Post Office Limited ("POL").
A. INTRODUCTION
2. This witness statement has been prepared in response to the Notice dated 16
March 2023 issued by the Inquiry pursuant to Section 21 of the Inquiries Act 2005
(the "Section 21 Notice") [BAF_1/1]. By the Section 21 Notice, the Inquiry required
that POL take the following steps by no later than 4pm on 23 March 2023:
a. Produce copies of all relevant outstanding documents responsive to Rule 9
Request No. 34 and paragraph 16 of Rule 9 Request No. 10.
b. Provide a witness statement in accordance with the Inquiry's Protocol on
Witness Statements addressing: (i) why the documents disclosed to the
Inquiry on 27 February 2023 were not located and/or disclosed previously;
and (ii) why the shared network drive referred to in Herbert Smith Freehills
LLP’s ("HSF") letters of 16 February 2023, 27 February 2023 and 14 March
2023 was not searched, and related enquiries regarding the same were not
undertaken, in response to Rule 9 Request No. 10.
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B. INTRODUCTION
3. The purpose of this witness statement is to provide POL's response to the two
questions set out at paragraph 2 of the Section 21 Notice.
4. I am the appropriate person to give this witness statement on behalf of POL,
particularly in the light of the fact that (a) I made the First, Second, Third and Fourth
Interim Disclosure Statements (to which I refer in this statement) and (b) as
explained therein, following the Board's appointment of HSF as POL's solicitors, I
am ultimately responsible for instructing HSF in respect of POL's response to each
of the requests made to POL by the Inquiry under Rule 9 of the Inquiry Rules 2006
("Rule 9 Requests") (or under Section 21 of the Inquiries Act 2005, as the case
may be), based on the instructions that I and POL's in-house lawyers, under the
supervision of POL's Inquiry Director, receive from our colleagues in the business
and ultimately the POL Inquiry executive steering committee and Board.
5. In this statement, I refer to:
a. Steps and/or decisions taken by POL in connection with the Rule 9
Requests, including with the assistance of HSF (and POL's other legal
representatives). POL's communications with HSF (and other legal
representatives) were and remain by their nature privileged. For the
avoidance of doubt, any reference to discussions should not be taken as a
waiver of that privilege, whether expressly or impliedly; and
b. Steps taken on behalf of POL by HSF and POL's other legal representatives
in connection with the Rule 9 Requests. For the avoidance of doubt, any
reference to steps taken by HSF and/or POL's other legal representatives
should not be taken as a waiver of privilege, whether expressly or impliedly.
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6. The facts in this witness statement are true, complete and accurate to the best of
my knowledge and belief. Where I refer to my beliefs and recollections, these
beliefs and recollections are based on the information provided to me by
colleagues at POL, by HSF and by others that have assisted POL in providing
disclosure to the Inquiry. This witness statement has been prepared with the
assistance of colleagues in POL's in-house legal team and HSF, the law firm
appointed to act on behalf of POL in the Inquiry ("POL's legal team").
7. Where I refer to specific documents in this statement, copies of those documents
are exhibited to this statement (as set out in the index below) in a series of
exhibits marked "[BAF_1/X]" and identified by the Inquiry's unique reference
number for that document (where available).
C. OVERVIEW
8. POL's response to the two matters raised in the Section 21 Notice is set out below
in this statement. I am conscious that this statement is relatively lengthy and goes
into considerable detail, including in relation to steps taken over a number of years.
This has been necessary in order to address the Inquiry’s questions properly and
fully. At the outset, by way of summary and to assist the Inquiry, I would therefore
make the following observations based on the advice and information I have
received:
a. the NBSC Knowledge Base was and is intended to be a comprehensive
repository of the guidance and instructions provided to NBSC operators for
answering calls;
b. POL's approach to locating guidance and instructions responsive to
Question 16 of Request No. 10 was focused on repositories which it knew
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to contain the NBSC Knowledge Base documents. Specifically, POL
focused on documents which had been disclosed in the Group Litigation,
and documents stored on the NBSC Knowledge Base itself (either on
SharePoint or Dynamics); and
. At that time, given the nature of the NBSC Knowledge Base, which was
accessible to, and accessed by, NBSC Helpline operators, POL did not
anticipate that searches conducted over mailbox data would yield additional
responsive documents (as contrasted to duplicative material, and/or drafts
that were not provided to operators and other technically non-responsive
material).
. In responding to Request No. 34, POL broadened its enquiries to account
for differences in scope compared to Request No. 10 (which was not limited
to guidance, training and instructions provided to NBSC Helpline operators),
including by running searches across certain mailbox data, and identified
the documents disclosed on 27 February 2023. The majority of these
documents derived from three emails, and based on a review conducted by
HSF, I understand that many of the documents were not in fact responsive
to either Request No. 10 or Request No. 34, following clarification from the
Inquiry provided on 16 March 2023.
. In broadening its enquiries, the P:Drive was identified as a potential
repository of documents responsive to Request No. 34 and/or Question 16
of Request No. 10. At this time, POL was unable to confirm whether steps
taken to harvest documents from the P:Drive in 2018/2019 had resulted in
these materials being fully uploaded to the GLO Relativity Database, and so
took urgent steps to harvest documents from the P:Drive for the purpose of
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responding to the Inquiry's requests. HSF has reviewed all documents from
a set of folders which appeared capable of holding relevant documents
(excluding duplicates). I understand that 156 documents harvested from
these P:Drive folders have been identified as responsive to Question 16 of
Request No. 10 and are being provided to the Inquiry on the same date as
this witness statement.
f. POL remains fully committed to responding to the Inquiry’s requests in a
timely and transparent manner and apologises for the inconvenience
caused on this occasion.
D. DOCUMENTS DISCLOSED TO THE INQUIRY ON 27 FEBRUARY 2023
9. In this section D, I address the matters raised in Paragraph 2(a) of the Notice,
namely why the documents disclosed by POL to the Inquiry on 27 February 2023
in response to Request No. 34 were not located and/or disclosed to the Inquiry
previously (in particular, in response to Request No. 10). I have structured this part
of my statement as follows;
a. The approach that was taken to locate documents responsive to Request
No. 10 (paragraphs 10 to 32 below).
b. The approach taken to locate documents responsive to Request No. 34, and
why it differed from the approach to Request No. 10 (paragraphs 33 to 41
below).
c. The nature of the additional documents disclosed on 27 February 2023
(paragraphs 42 to 49 below).
Approach to Rule 9 Request No. 10
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10.On 18 February 2022, POL received Request No. 10 containing 29 questions
covering a wide range of issues of relevance to Phases 2 and 3 of the Inquiry
[BAF _1/2]. Question 16 of Request No. 10 asked POL to "Please provide details
of any guidance, training or instructions given to those responsible for operating
the Network Business Support Helpline (“Helpline”) since the commencement of
the national roll out."
11.POL was required to respond to Question 16 of Request No. 10 by 15 April 2022
(together with questions 5-15 and 17-24, whereas the balance was due on 18
March 2022). POL submitted its response to Question 16 of Request No. 10 on 14
April 2022. The searches that POL performed for the purpose of identifying
documents and information of relevance to Question 16 of Request No. 10 are set
out at page 62 of POL's first interim disclosure statement dated 27 May 2022 (the
"First Interim Disclosure Statement") [BAF_1/3].
12.In devising its approach for responding to Request No. 10, POL's legal team noted
that Question 16 of Request No. 10 sought details of materials that were actually
‘given to' those responsible for operating the NBSC as opposed to, for example,
materials that were created or prepared in relation to the NBSC more broadly. This
feature of Question 16 of Request No. 10 informed POL's approach to responding
to the request.
13.POL's starting point for identifying guidance, training or instructions given to those
responsible for operating the Helpline since the commencement of the national roll
out was to consider the disclosure previously made during the proceedings
conducted pursuant to a Group Litigation Order made on 22 March 2017 (the
"Group Litigation").
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14.As I described in the First Interim Disclosure Statement, I am advised that in or
around 2017 POL arranged for copies of the data held on its file servers (totalling
approximately 9.5 TB of compressed zip files) to be copied and placed onto a
separate Network Attached Storage ("NAS") Drive (see paragraph 18 of the First
Interim Disclosure Statement).
15.POL then used a Relativity database to collate documents which were harvested
from the NAS to allow for searches and reviews to be conducted for the purposes
of disclosure in the Group Litigation (the "GLO Database"). The GLO Database
contains in excess of 20 million documents.
16. Disclosure in the Group Litigation was made in stages. In the second stage ("Stage
2"), the Claimants sought a copy of the ‘NBSC Knowledge Base’. As I have
mentioned, I understand that guidance and instructions were (and are) provided to
Helpline operators through the Knowledge Base, which was (and is) used by
Helpline operators when answering questions from end users of the Horizon IT
system ("Horizon"). I understand that the Knowledge Base was intended to be a
comprehensive repository of the guidance and instructions used by Helpline
operators when answering calls.
17.In response to that request in a letter to Freeths LLP dated 18 May 2018 [BAF_ 1/4],
Womble Bond Dickinson ("WBD"), on behalf of POL, explained that they had
searched the SharePoint Site "Branch and Customer Information" for relevant
documents by "reviewing all Visio files (which Post Office typically uses to generate
process maps) and searching for documents which contain "NBSC" in the
document title." They explained that POL had collated 903 articles which it believed
to have been referred to by the NBSC but noted that "due to the nature of the
documents it is unclear if they were final versions which were referred to, if they
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relate to the NBSC or another function, or when they were in use". I am advised
that these documents were tagged "10. NBSC" in the GLO Database by WBD prior
to disclosure in the Group Litigation.
18.In the fourth stage of disclosure ("Stage 4") the Claimants sought Knowledge Base
Articles ("KBAs") from between January 2000 and December 2011, and on 30
August 2019 [BAF_1/5] POL gave disclosure of KBAs, together with other
documents which may have been of interest to the Claimants (as set out at
paragraph 20 below). In a letter to Freeths LLP dated 30 August 2019, WBD,
explained that "Knowledge Base Articles (KBAs) form the NBSC call handler's
Knowledge Base". WBD went on to explain that they had been informed by Kendra
Dickinson, a Senior Service and Performance Manager in POL's Branch and
Customer Support who had worked with the NBSC team for over 10 years, that
KBAs may have been stored within two SharePoint sites: "Branch and Customer
Information Team" and "NBSC KBA".
19.WBD explained that of the 29,437 documents on the Branch and Customer
Information Team SharePoint site, 16,020 had already been disclosed in POL's
Stage 2 Disclosure. According to WBD's letter of 18 May 2018 (as referred to in
paragraph 16 above), 903 of these were disclosed in relation to the NBSC
Knowledge Base, while approximately 15,000 were Horizon Online Help HTML
files. Of the remaining 13,417 undisclosed documents on the Branch and Customer
Information Team SharePoint site, 3,905 fell within the relevant date range (1
January 2000 to 31 December 2011), of which 2,171 were disclosed in Stage 4
after a review for privilege and relevance. The NBSC KBA SharePoint site (which
I am advised was harvested on 15 May 2019) contained a further 3,304
documents, of which 2,882 were disclosed in Stage 4 after a review for privilege
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and relevance. All documents harvested and disclosed from these two SharePoint
sites were uploaded onto the GLO Database.
20.WBD also stated that POL had included within its disclosure documents which
were not strictly KBAs but which may have been of interest to the Claimants.
21.Overall, POL's disclosure in the Group Litigation in respect of KBAs (and other
documents included in that class which were not strictly KBAs but may have been
of interest to the Claimants) covered a period from January 2000 until 15 May 2019
(when the NBSC KBA SharePoint Site was harvested) and comprised 4,993
documents (many of which were not in fact KBAs). I am advised that these
documents were tagged "26. KBAs" in the GLO Database by WBD prior to
disclosure in the Group Litigation.
22.1 therefore understand that the documents disclosed in the Group Litigation relating
to the Knowledge Base (whether disclosed in Stage 2 or Stage 4 of the disclosure
exercise in the Group Litigation) were tagged as either "NBSC" or "KBAs".
23.For the purpose of responding to Question 16 of Request No. 10 POL conducted
keyword searches across the documents disclosed in the Group Litigation with
these tags, and all 2,857 keyword responsive documents (including family
documents) were manually reviewed to identify documents responsive to Question
16 of Request No. 10.
24.As POL's disclosure in the Group Litigation only went up to May 2019, for the
purpose of responding to Question 16 of Request No. 10 (which covered the
relevant period for the Inquiry’s Completed List of Issues i.e. from the first pilot of
the Horizon system until 1 June 2021), in order to understand how KBAs were
accessed by Helpline operators and to identify KBAs created or amended since
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2019, POL's legal team spoke to the Senior Service and Performance Manager
who, as I note in paragraph 18 above, had assisted in respect of POL's disclosure
on this aspect in the Group Litigation. POL's legal team also spoke to the Service
and Support Knowledge and Information Manager, who had been responsible for
managing KBAs on behalf of the BSC (as the NBSC has been known since 2018).
These discussions informed the basis of POL's response to Question 16 of
Request No. 10, including the narrative response contained in the appendix to the
third letter from HSF to the Inquiry dated 14 April 2022 [BAF_1/6].
25.As explained in that response, the NBSC Helpline was run by the Royal Mail Group
(and/or its predecessors) ("RMG") from its inception until 2014, and prior to 2014,
KBAs and other guidance for the NBSC were accessed through an RMG system
called 'Remedy’. I understand that RMG has stated that it has not retained any data
from Remedy (as explained in a disclosure note dated 10 June 2022 prepared by
POL's criminal law solicitors, Peters & Peters, shared with the Inquiry on 4 July
2022 [BAF_1/7]).
26.POL also explained that in 2014, the KBAs that were on Remedy (at that date)
were transferred to POL's NBSC KBA SharePoint site and from then onwards they
were accessed through a platform called 'Microsoft Dynamics’. Since 2018, any
new KBAs that were created were created and managed directly in Dynamics,
while KBAs stored on the NBSC KBA SharePoint site were transferred to Dynamics
in December 2021. I understand that the NBSC KBA SharePoint site remained live
following the transfer.
27.Accordingly, as I explained in the First Interim Disclosure Statement, in order for
POL to respond to Request No. 10 the NBSC KBA SharePoint site was harvested
again in April 2022, to capture KBAs created since 2019.
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28. The Branch and Customer Information Team SharePoint site was not re-harvested
at this stage as POL understood from the Service and Support Knowledge and
Information Manager that KBAs created since 2018 were stored either on the
NBSC KBA SharePoint site or directly on Dynamics, meaning that any responsive
documents would be identified from those repositories.
29.In total, POL produced 286 documents to the Inquiry in response to Question 16
of Request No. 10 on 15 April 2022 (including the Excel spreadsheet which, as
explained in the narrative response, contained the text of the 465 distinct KBAs
identified as relating to the use and/or operation of Horizon as at April 2022). These
documents covered a date range from 22 August 2005 to 1 June 2021, and topics
including balancing and investigating discrepancies. This was as part of a broader
set of 6,582 documents that POL produced to the Inquiry in response to to Request
No. 10.
30.On 24 November 2022, POL produced one further document in response to
Question 16 of Request No. 10 (together with other documents relevant to other
questions within Request No. 10) [BAF_1/8]. This document was identified by
conducting searches across a further 12 SharePoint sites that had subsequently
been identified as potentially containing documents responsive to the ‘Advice and
Assistance’ questions in Request No. 10 (further details of which are set out at
Annex I to this statement). This followed an audit of all active and archived
SharePoint sites on POL's network. One further document was identified and
disclosed on 3 March 2023 as part of a hard copy document assurance exercise
being carried out over documents at POL's Chesterfield site [BAF_1/9].
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31.POL did not at the time of undertaking its work to respond to Question 16 of
Request No. 10 conduct keyword searches across custodian mailbox data in
respect of Question 16 of Request No. 10. POL's legal team understood from their
discussions with the Senior Service and Performance Manager and the Service
and Support Knowledge and Information Manager that Helpline operators
accessed guidance, training and instructions directly through the Knowledge Base.
While POL's legal team anticipated that emails might have contained drafts of
guidance, training and instructions, POL's legal team considered that it was
unlikely that mailbox data would contain details of guidance, training and
instructions actually given to Helpline operators. Where mailbox data was
considered likely to contain material responsive to other questions in Request No.
10, searches were carried out for the purposes of these questions (as set out in
the First Interim Disclosure Statement).
32.In all the circumstances, and based on what POL knew at the time (though I was
not personally involved), I believe that POL's searches in respect of Question 16
of Request No. 10 were reasonable and proportionate in identifying guidance,
training and instructions given to Helpline operators.
Approach to Rule 9 Request No. 34
33.On 26 January 2023, POL received a request from the Inquiry in the following
terms:
"Copies of relevant scripts provided to members of (a) the NBSC (b) the BSC
(c) any other person or team within the Post Office who provided advice,
assistance or support to end-users of the Horizon IT System, between 1999
and 2014.
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For this Rule 9 Request, the definition of a script includes (a) instructions and
(b) other written guidance to Post Office staff on how to handle calls from end-
users of the Horizon IT System..." (Request No. 34) [BAF_1/10].
34.1n devising its approach to responding to Request No. 34, POL noted that, although
Question 16 of Request No. 10 and Request No. 34 overlap, they are different in
scope, in that Request No. 34 sought scripts provided to any other person or team
within the Post Office who provided advice, assistance and support, not just those
provided to the NBSC/BSC (in contrast to Request No. 10). In addition, Request
No. 34 referred to members of the NBSC/BSC broadly, not just those responsible
for operating the Helpline.
35.1 understand that, at the time, POL's legal team was not aware of relevant scripts,
guidance and instructions having been shared with people and teams within POL
who gave ‘advice, assistance or support to end-users of the Horizon IT' other than
the NBSC. However, if such scripts, guidance and instructions had been shared
with people other than the NBSC, POL considered that they would have likely been
shared by email as individuals other than those responsible for operating the NBSC.
Helpline would have been unlikely to have access to the SharePoint sites where
KBAs were held. POL therefore considered that Request No. 34 warranted broader
searches, including over mailboxes, to identify any scripts, guidance or instructions
given to other people or teams which might be responsive to Request No. 34.
36.Searches were carried out over five custodian mailboxes, four email distribution
lists, and 24 SharePoint sites (including, for completeness, the version of the
Branch and Customer Information Team site held on the GLO Database) in order
to respond to Request No. 34. POL's index of hard copy documents stored at Oasis
was also considered. A full account of the searches carried out in response to
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Request No. 34 is set out at Annex II to this statement. Although these searches
were carried out in respect of Request No. 34, where POL identified documents
that were also or otherwise responsive to Request No. 10, these were disclosed
too.
37.While conducting checks in relation to documents identified through these
searches, POL identified three host emails from 2013/14 which attached large
sets of documents. Those emails are [BAF_1/11] [BAF_1/12] [BAF_1/13]:
Document ID I Date Email Attachments
POL-0113548 I 26 April 2013 I John Cawthorn to Kendra 174 in two zip files
Dickinson. (and junk image
Subject: POLO Training files). A zip titled
'NBSC Brief’ contains
103 documents.
POL-0113549 I 3 April 2014 Kendra Dickinson to POL Core Info I A zip file with 257
Management Team. documents described
Subject: FW: NBSC processes in the email as 'Kb
Process Maps'.
POL-0113550 I 29 April 2014 I POL Core Info Management Team _ I A zip file with 201
to Kendra Dickinson. documents described
Subject: FW: NBSC processes in the email subject
as 'NBSC process's’
38. These host emails are not themselves responsive to Question 16 of Request No.
10 or Request No. 34 as they are not scripts or guidance ‘given to' the NBSC,
and 324 of the attachments did not contain the keywords set out in Annex II to
this statement. For this reason the host emails themselves were not disclosed on
27 January 2023, but they are exhibited to this statement and separately
produced to the Inquiry today for completeness.
39. Two of these host emails (POL-0113549 and POL-0113550) indicate that the
attachments had been given to NBSC Helpline operators, even though the host
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emails themselves were not directed to NBSC Helpline operators. It is not clear to
me whether the first email (POL-0113548) was sent in relation to training about
the NBSC, as opposed to training given to the NBSC, but POL erred on the side
of caution and (to the extent the documents were not duplicates) produced
documents in the zip file attached to this email titled ‘'NBSC Brief.
40.Cumulatively, these three host emails attach 632 documents, of which 502
41.
documents were produced to the Inquiry (the balance of the attachments were
either duplicates, or attachments to POL-0113548 which were not responsive).
Accordingly, the attachments to these three emails account for the large majority
of the 707 documents produced by POL on 27 February 2023.
I further note:
a. in addition to the 502 email attachments described above, 160 documents
produced on 27 February 2023 were emails and/or attachments, bringing
the total number of mailbox documents to 662. Of the 160 additional
mailbox documents I note:
i. approximately 70 documents were drafts and/or email discussion —
meaning these 70 documents were not technically responsive to
Request No. 10 and/or Request No. 34. I explain why these
documents were provided at 43.a; and
ii. 15 documents did not relate to ‘the Horizon IT [system] nor any
other aspect of the issues which the Inquiry is considering' meaning
that these documents were also not technically responsive to
Request No. 10 and/or Request No. 34. The Inquiry confirmed in its
letter dated 16 March 2023 that it did not wish to be provided with
such documents [BAF_1/14];
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b. 11 documents were identified through the review of hard copy documents
stored at Oasis; and
c. the remaining 33 documents originated from SharePoint sites and were
identified through the searches set out in Annex II to this statement.
This further reflects that the three emails discussed at paragraph 37 account for
the large majority of the 707 documents produced by POL on 27 February 2023.
Responsiveness of documents produced on 27 February 2023
42. POL produced 707 documents to the Inquiry on 27 February 2023 in relation to
Request No. 10 and/or Request No. 34. I note that:
a. 71 documents provided to the Inquiry on 27 February 2023 (and marked
‘Example Documents’) consisted of draft documents and secondary records
such as emails discussing possible changes to scripts. These documents
were not responsive to either Request No. 10 and/or Request No. 34, and
were identified as such at the time of production, but they were nonetheless
produced to the Inquiry in case of interest or assistance; and
b. a further 41 documents produced on 27 February 2023 were exact
duplicates (based on MD5 hash value and/or 100% textual near duplicate
analysis) of other produced documents, as identified in POL's letter to the
Inquiry dated 14 March 2023 [BAF_1/15]. Of these:
(i) 36 documents were 100% textual duplicates of at least one other
document within the production. These 36 documents could be
divided into 11 duplicate groups — meaning 11 documents were
‘unique’ whereas the other 25 were duplicative;
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(ii) 3 documents had the same MD5 hash value as documents that have
been previously produced to the Inquiry, and so were duplicative;
and
(iii) I 2 documents were 100% textual duplicates of documents that had
been previously produced to the Inquiry, and so were duplicative.
43.Taking into account the examples and duplicates described in paragraph 42,
ultimately 621 unique documents were produced by POL to the Inquiry on 27
February 2023 in response to Question 16 of Request No. 10 and/or Request No.
34 (this number reflects that there was overlap between the 71 examples described
in paragraph 42.a and the duplicates described in 42.b).
44.As noted in the letter from HSF to the Inquiry dated 27 February 2023, when
producing documents to the Inquiry on that date POL adopted a broad approach
to relevance [BAF_1/16].
45.The production list dated 27 February 2023 includes various documents which are
technically responsive to Question 16 of Request No. 10 (in that they constituted
guidance, training or instructions given to those responsible for operating the
Network Business Support Helpline), but which do not relate in any way to the
Horizon IT system nor any other aspect of the issues which the Inquiry is
considering. Examples of such documents are exhibited hereto and marked
[BAF_1/17] [BAF_1/18] [BAF_1/19] [BAF_1/20], namely:
a. POL-0111734 — which relates to travel insurance;
b. POL-0111745 — which relates to identification checking services;
c. POL-0112129 - which relates to alarm systems; and
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d. POL-0111689 - which relates to notification of non-critical unplanned
branch closures.
46.POL identified the above example documents to the Inquiry in its letter dated 14
March 2023, and sought clarification as to the scope of documents to be produced
in relation to the then ongoing review of documents from the P:Drive (the P:Drive
is discussed in Section E of this statement). By letter dated 16 March 2023, the
Inquiry confirmed that it did not wish to be provided with documents that “do not
relate in any way to the Horizon IT [system] nor any other aspect of the issues
which the Inquiry is considering’.
47.1n the interests of assisting the Inquiry, POL has conducted a review of the 621
documents produced on 27 February 2023, with a view to assessing which of these
would not have been produced in response to Question 16 of Request No. 10 in
the light of the Inquiry's clarification provided on 16 March 2023 (a ‘post-production’
review). When conducting this post-production review POL took a broad approach
and erred on the side of relevance.
48.The results of POL's post-production review are reflected in Annex Ill to this
statement. These results are provided to assist the Inquiry in its consideration of
the matters discussed in this statement and the documents produced on 27
February 2023.
49.As Annex III shows, if POL had limited its production of documents on 27 February
2023 to exclude documents that “do not relate in any way to the Horizon IT [system]
nor any other aspect of the issues which the Inquiry is considering”, only 316
documents would have been produced. Of these 316 documents, approximately
204 documents contain substantive information about the Horizon IT system and/or
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other relevant issues, and approximately 112 documents contain only peripheral
or passing references to the Horizon IT system and/or other relevant issues. This
means that approximately 305 documents (that is, around half of the documents
produced on 27 February 2023) are not responsive to Question 16 of Request No.
10 as clarified by the Inquiry on 16 March 2023.
E. THE SHARED DRIVE REFERRED TO IN HSF’s LETTER OF 16 FEBRUARY 2023
50.In this section E, I address the matters raised in Paragraph 2(b) of the Section 21
Notice, namely why the shared network drive referred to in HSF's letters of 16
February 2023, 27 February 2023 and 14 March 2023 was not searched, and
related enquiries regarding the same were not undertaken, in response to Request
No.10.
51.1 understand that certain personnel and teams within POL have had access to and
use of specific network shared drives for the purpose of storing documents. One
such network shared drive, which is generally referred to as the 'P:Drive' and/or
the 'N:Drive' (‘the P:Drive'), could be accessed and used by the NBSC.
52.At paragraphs 11-32 of this statement I have outlined the approach which POL
adopted in order to respond to Question 16 of Request No. 10. In summary, this
was to focus on documents contained in the NBSC Knowledge Base which had
been disclosed in the Group Litigation, and documents stored on the NBSC
Knowledge Base (either on SharePoint or Dynamics) since the Group Litigation
disclosure (for the reasons given in paragraph 13 above). POL did not undertake
specific searches focused on the P:Drive for the purpose of Question 16 of Request
No. 10.
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53.When Request No. 34 was received on 26 January 2023, POL's legal team
reflected on the work that had previously been undertaken in respect of Request
No. 10, specifically Question 16, and (given the difference in scope between
Request No. 10 and Request No. 34) considered whether it was necessary to
conduct additional searches to locate documents that might be responsive to
Request No. 34. POL's legal team identified that the P:Drive was used to store
documents by members of the NBSC and that steps had been taken to harvest
documents from the P:Drive for the purposes of the Group Litigation.
Steps taken in respect of the P:Drive for the purposes of the Group Litigation
54.As I set out at paragraph 14 above, and described in POL's First Interim Disclosure
Statement, I am advised that copies of the data held on POL’s file servers (totalling
approximately 9.5 TB of compressed zip files) were copied and placed onto the
NAS Drive, which included documents from network shared drives.
55.1 am advised that between February and September 2018, as part of the broader
document harvesting exercise undertaken for staged disclosure in the Group
Litigation, WBD took steps to obtain and upload to the GLO Database three
network shared drives from the NAS Drive — namely, the P:Drive (which, as noted
above, was also known as the N:Drive), the L:Drive (also known as the Y:Drive)
and the T:Drive. By a letter dated 23 July 2018 from WBD to Freeths LLP, WBD
stated that the P:Drive had been located and that work had begun to extract it
[BAF_1/21].
56. These three network shared drives amounted to approximately 350GB of the 18TB
data held on the NAS Drive. In September 2018, Consilio (who was POL's e-
Discovery provider in the context of the Group Litigation) informed POL that it was
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seeking to confirm whether and how these shared drives could be harvested in
isolation for the purposes of the Group Litigation, as opposed to harvesting all data
held on the NAS Drive (that is, the full 18TB of data from POL's servers).
The P:Drive and Request No. 34
57.While preparing to respond to Request No. 34, POL consulted its records and
identified (following a review of analysis prepared by WBD for POL in September
2022 in relation to the harvesting exercise undertaken in the context of the Group
Litigation) that WBD had been unable to confirm whether the harvesting of the
P:Drive was undertaken and/or had been successfully completed in 2018 and
2019, nor whether documents from this drive had been uploaded (whether in full
or in part) to the GLO Database.
58. In light of this information, when responding to Request No. 34 in early February
2023, POL's legal team sought to verify whether documents from the P:Drive had
been harvested for the Group Litigation and, if so, whether they were held in the
GLO Database. POL drew this issue to the attention of the Inquiry in a letter dated
16 February 2023 [BAF_1/22].
59. Throughout February 2023, POL's legal team consulted with relevant third party
providers (including KPMG, WBD and Consilio) with a view to confirming whether
documents from the P:Drive had been harvested for the Group Litigation and/or
transferred to the GLO Database. I understand that, in order to try to answer this
question, POL, KPMG, WBD and Consillio variously conducted searches over
historical records relating to the Group Litigation, attempted to check file paths on
the NAS Drive and ran searches in the GLO Database.
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60.By mid-to-late February 2023, despite these enquiries, no further light had been
shed on the question. However, in the course of the enquiries, POL was able to
confirm that the documents from the P:Drive had been harvested and stored on
the NAS Drive, as I have described above at paragraph 54. In these circumstances,
POL arranged for the NAS Drive to be transferred to KPMG so that KPMG could
isolate, harvest and process documents from the P:Drive afresh before uploading
them to POL's Relativity Databases.
61. The following correspondence was subsequently exchanged between POL and the
Inquiry in relation to Request No. 34, Request No. 10 and/or the P:Drive:
a. By letter dated 27 February 2023, POL provided an update to the Inquiry
and sought an extension of time until 13 March 2023 for the specific purpose
of harvesting, processing, uploading to Relativity, running searches over
and reviewing documents from the P:Drive.
b. At approximately 13:51 on 13 March 2023, via email, the Inquiry responded
to POL's letter dated 27 February 2023 and requested that any further
documents responsive to Request No. 34 be provided no later than the end
of that day. A copy of that email is exhibited at [BAF_1/23] and a reply sent
to the Inquiry by HSF at approximately 17:03 on the same date is exhibited
at [BAF_1/24].
c. By letter dated 14 March 2023, POL responded to the Inquiry's email dated
13 March 2023 providing an update on the steps outlined above at
paragraphs 57-60 and seeking an extension until 23 March 2023.
d. On 16 March 2023, POL received the Section 21 Notice.
Documents harvested from the P:Drive for Request No. 34 and/or Request No. 10
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62.In February to March 2023, POL arranged for a total of 17,882 documents stored
across 16 folders on the P:Drive to be harvested and uploaded onto its Relativity
platform. These folders (which are listed at Annex II to this statement) were the
folders which POL anticipated based on their description would be most likely to
contain documents of potential relevance to Question 16 of Request No. 10 and/or
Request No. 34. The documents from these (16) folders were uploaded onto POL's
Relativity platform on 7 March 2023. Based on analysis POL's eDiscovery provider
has undertaken since 7 March 2023, I understand that:
a. approximately 3,658 of the 17,882 documents harvested in February to
March 2023 were exact duplicates (with the same MD5 hash values) as
other documents within the harvested folders; and
b. a further unique 2,289 of the 17,882 documents harvested in February to
March 2023 were exact duplicates (with the same MD5 hash values) as
other documents already stored in POL's Relativity Databases (meaning
that POL had already harvested copies of at least 2,289 documents of the
17,882 documents).
63. Accordingly, of the 17,882 P:Drive documents harvested in February and March
2023, no more than 11,875 were potentially 'new' to POL's Relativity Databases. I
say 'no more than' 11,875 because the de-duplication exercise described above
was based on MD5 hash value only. No textual duplicate analysis nor any other
form of deduplication was applied, to avoid delaying the review of documents for
relevance. The actual number of documents that contain new content may be lower
than 11,875. It is unclear whether any of duplicates already in the GLO Database
had been harvested from the P:Drive for the GLO — they may originate from another
source.
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Documents to be produced from the P:Drive
64.After the documents harvested from the P:Drive were uploaded to Relativity
Databases, POL's legal team checked the contents of each folder (by scanning the
document lists and reviewing a sample of documents) and ascertained that only
three of 16 folders appeared likely to hold documents potentially responsive to
Question 16 of Request No. 10 and/or Request No. 34. These folders are entitled:
"365 Dynamics Categories ARCHIVE " (specifically the Branch KBA subfolder),
"Core K Base" and "Dynamics SME" (specifically the Branch KBA subfolder).
Following de-duplication and the exclusion of an irrelevant subfolder, these three
folders contain approximately 7,180 documents.
65.All of the approximately 7,180 documents described in the preceding paragraph
have been subject to manual review by HSF for relevance in relation to Question
16 of Request No. 10 and/or Request No. 34. Of these documents, POL has
produced approximately 156 documents in response to Question 16 of Request
No. 10 on 23 March 2023. No documents will be produced in response to Request
No. 34. I make the following observations in relation to the produced documents in
case these observations might be of assistance to the Inquiry:
a. All but two of the documents have metadata dates in 2017 and 2018 (one
document is dated in each of 2012 and 2013) — this is after the period of
time relevant to Request No. 34;
b. Some of the documents may be drafts, but as it is not clear from the face of
the documents, POL has taken a cautious approach and produced them in
any event;
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c. POL has had regard to the clarification provided by the Inquiry on 16 March
2023, while also construing Question 16 of Request No. 10 and Request
No. 34 broadly; and
d. The intended audience of approximately 45 documents appear to be end-
users of the Horizon IT system themselves, rather than the NBSC (for
example, some documents state that the reader themselves should do
certain things, eg ‘check that you have' done x). POL can identify these for
the Inquiry if it would be considered useful.
66.1 am not aware of any documents responsive to Question 16 of Request No. 10
and/or Request No. 34 which are yet to be produced. For completeness, I note that
POL is continuing to carry out general assurance exercises over various document
repositories, as explained in POL's second, third and fourth interim disclosure
statements dated 18 October 2022, 30 November 2022 and 12 January 2023
[BAF_1/25] [BAF_1/26] [BAF_1/27] [BAF_1/28] [BAF_1/29] [BAF_1/30]. While I
have no reason to believe that documents responsive to Question 16 of Request
No. 10 and/or Request No. 34 would be contained in those repositories, any
documents that are subsequently identified will be produced to the Inquiry as soon
as reasonably possible.
67.POL is committed to ensuring that its disclosure exercise in the Inquiry is
sufficiently thorough to ensure that relevant documentation can be provided to the
Inquiry. To that end, POL is well advanced in the hard copy data assurance it
indicated it was carrying out in the Third Interim Disclosure Statement and Fourth
Interim Disclosure Statement and has provided a number of additional responsive
documents to the Inquiry. I anticipate that POL will be in a position to provide an
update to the Inquiry with further details of the work that has been carried out in
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relation to the assurance exercise (and any work that remains to be done) in
advance of the recommencement of the phase 3 hearings in May.
68.Also, in circumstances where POL has not been able to confirm whether
documents were harvested and uploaded to Relativity from the P:Drive in the
context of the Group Litigation, POL intends to conduct additional searches over
the folders uploaded from the P:Drive to ascertain whether any documents might
be responsive to Rule 9 Requests (to the extent that any such documents have not
already been disclosed).
69.Further, based on updates provided by HSF, I understand that the remaining
folders on the P:Drive will also be harvested and uploaded to Relativity and
considered for relevance to the Rule 9 Requests that POL has to date received
from the Inquiry. Specifically, POL proposes to:
a. Exclude folders which are plainly likely to be irrelevant (such as the folders
titled ‘Annual Leave' and ‘Staffing Issues’), process the documents from
remaining folders from the P:Drive, deduplicate this material against the
documents already in POL's Relativity Databases, and upload any new
documents to the Inquiry Database;
b. Check a sample of documents from each newly harvested P:Drive folder to
confirm what types of documents they hold, and whether they may
potentially hold documents responsive to one or more Rule 9 Requests. This
step is intended to act as a safety check and to ensure that any potentially
relevant folders are considered as a priority. It will also inform the keyword
searches that POL anticipates will be necessary to conduct across each
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such folder. At least one folder, titled 'RM Archive Folders’ will be prioritised
based on the title; and
c. Run searches over the P:Drive as informed by (and prioritising any folders
identified in) the exercise described at step b above.
Conclusion
70. I can understand why the Inquiry has sought a full explanation of the circumstances
which gave rise to the two issues in respect of which this statement has been
sought.
71.So far as the additional disclosure made in response to Request No. 34 is
concerned, I apologise on behalf of POL for any adverse impact that the disclosure
of documents on that date which fell within the scope of Question 16 of Request
No. 10 had on the Inquiry and those participating in the Inquiry. In particular, I
apologise on behalf of POL for the fact that this disclosure was provided at a point
in the hearings where witnesses were about to give evidence on matters to which
the documents disclosed may have been relevant. I have explained why POL
considers that its approach to disclosure at the time of responding to Question 16
of Request No. 10 was reasonable in all the circumstances, but I recognise the
potential difficulty that POL's disclosure on 27 February 2023 created for the
Inquiry's schedule. I have highlighted the challenges about POL's existing data
repositories to the executive and appropriate board forums. POL will, of
course, do all that is required to assist the Inquiry with steps required as a result,
such as the provision of any additional witness statements or assistance.
72. As for the P:Drive, I also apologise on behalf of POL for any adverse impact
that may be caused to the Inquiry, core participants or any other persons by
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the late disclosure of the 156 documents produced today. It is difficult to provide
a firm estimated timeframe for completion of the exercise described above at this
stage (that is, before the volume of any potentially relevant documents has been
ascertained). However, POL will endeavour to complete this exercise as promptly
as is reasonably practicable, and by 28 April 2023 if possible. POL will provide the
Inquiry with updates in relation to the results of the steps outlined at paragraph 69
on an ongoing basis and will provide any updated estimated timeframe for the
completion this exercise at the earliest opportunity.
73. Within the same timeframe, POL will also continue, together with WBD, to look
into the circumstances in which it appears that the P:Drive may not have been
uploaded to the GLO Database, and make enquires in relation to other potential
network shared drives harvested for the GLO to ensure that none were overlooked
(although POL is not currently aware of any issue in this respect).
74.Consistent with my offer in the Second Interim Disclosure Statement in relation to
the documents that were the subject of that statement (the Omnidox documents),
were the Inquiry to wish to be provided with access to the full contents of the
P:Drive responsive to the search term ‘Horizon’, prior to the review for relevance
being complete, POL would be willing to provide the Inquiry with full access,
following receipt of a Rule 9 Request in relation to the same.
Statement of Truth
I believe the content of this statement to be true:
Signed:
Dated: 23 March 2023
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Index to the First Witness Statement of Benjamin Andrew Foat on behalf of
Post Office Limited
No.
URN
Document Description
Control Number
Section 21(2) Notice of the Inquiries Act
2005 (16 March 2023)
Request No. 10 - Request pursuant to Rule
9 of the Inquiry Rules 2006 (18 February
2022)
Interim Disclosure Statement on behalf of
Post Office Limited (27 May 2022)
Letter from Womble Bond Dickinson to
Freeths LLP re Stage 2 Disclosure List (18
May 2018)
POL-0038268
POL00037060
Letter from Womble Bond Dickinson to
Freeths LLP re Stage 4 Disclosure List (30
August 2019)
POL-0033995
Appendix to the Third Letter to the Inquiry
(14 April 2022)
Further Disclosure Note: NBSC Logs (10
June 2022)
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Third Letter to Inquiry re Request No. 10 (24
November 2022)
Letter from Herbert Smith Freehills LLP to
the Inquiry re Supplemental Production of
Documents pursuant to Rule 9 (3 March
2023)
10
Request No. 34 - Request for Information
pursuant to Rule 9 (26 January 2023)
11
Email Correspondence between Kendra
Dickinson and John Cawthorn re POLO
Training (26 April 2013)
POL-0113548
12
Email Correspondence between Kendra
Dickinson and the POL Core Info
Management Team re NBSC Processes (28
January 2014 — 3 April 2014)
POL-0113549
13
Email Correspondence between Kendra
Dickinson and the POL Core Info
Management Team re NBSC Processes (29
April 2014)
POL-0113550
14
Letter from the Inquiry to Gregg Rowan re
Section 21 Notice (16 March 2023)
15
Letter from Herbert Smith Freehills LLP to
the Inquiry re Request No. 34 (14 March
2023)
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16 Letter from Herbert Smith Freehills LLP to
the Inquiry re Request No. 34 (27 February
2023)
17 I POL00106280 I Questions re Travel Insurance POL-0111734
18 I POLO00106291 I Post Office Identity Checking Service Form I POL-0111745
19 I POLO0106674 I Alarm System Protocol POL-0112129
20 I POL00106235 I Notification of a Non-Critical Unplanned POL-0111689
Branch Closure Flowchart
21 Letter from Womble Bond Dickinson to POL-0038341
Freeths LLP re General Comments on
Disclosure (23 July 2018)
22 Letter from Herbert Smith Freehills LLP to
the Inquiry re Request No. 34 (16 February
2023)
23 Email from the Inquiry to POL re Request
No. 34 (13 March 2023)
24 Email from Herbert Smith Freehills LLP to
the Inquiry re Request No. 34 (13 March
2023)
25 Second Interim Disclosure Statement on
behalf of Post Office Limited (18 October
2022)
26 Annex 1 to the Second Interim Disclosure
Statement - Hard Copy Document
Repositories (18 October 2022)
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27
Annex 2 to the Second Interim Disclosure
Statement - Approach for responding to
Requests No. 12 to No. 23 (18 October
2022)
28
Annex 3 to the Second Interim Disclosure
Statement - Summary Chronology of Key
Events (18 October 2022)
29
Third Interim Disclosure Statement on
behalf of Post Office Limited (30 November
2022)
30
Fourth Interim Disclosure Statement on
behalf of Post Office Limited (12 January
2023)
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Annex I - Additional searches in respect of Rule 9 Request No. 10
The purpose of this Annex I is to provide an overview of the additional searches
that POL carried out across newly identified SharePoint sites following an audit
of all active and archived SharePoint sites on POL's network which led to the
production of a further 213 documents relevant to Questions 11-20 of Request
No. 10 on 24 November 2022, one of which was responsive to Question 16.
The initial searches that POL carried out when Request No. 10 was first
received are set out in the First Interim Disclosure Statement.
POL reviewed a list of all active and archived SharePoint sites to identify those
which, based on their name, appeared as though they might contain documents
responsive to Question 16 of Request No. 10. A full list of the searches
performed by POL in this context, and the SharePoint sites over which these
searches have been conducted, is set out below. All documents responsive to
these searches were subject to manual review. One document was identified
as responsive to Question 16 of Request No. 10 and was produced to the
Inquiry.
SharePoint Ss Searches
Branch Support Advisor Updates Search terms: "Horizon" OR
5 "Discrepanc*" OR "Shortfall" OR
K ledge Article Update
Sonn ° a 5 rere ne ° led "Helpline" OR "Transaction Correction"
ervice an ort Knowledge
Base uPP 9 Date range: Before 1 January 2021
BSC Coaching Search terms: "Guidance" OR "Guide"
BSC Team OR "Training" OR "Instructions"
BSC Team Leaders Date range: Before 1 January 2021
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Emma BSC Team Sept 21
Emmas BSC Team
Nicks BSC Team
Service Support Contact Centres
Contact Centre 145
Contact Centre
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1.1
21
2.2
2.3
24
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Annex Il — Searches in respect of Rule 9 Request No. 34
INTRODUCTION
The purpose of this Annex II is to provide an overview of the approach that POL
has adopted for responding to Rule 9 Request No. 34 dated 26 January 2023.
REQUEST NO. 34
By Request No. 34, the Inquiry requested that POL produce copies of relevant
scripts provided to members of (a) the NBSC (b) the BSC (c) any person or
team within the Post Office who provided advice, assistance or support to end-
users of the Horizon IT System, between 1999 and 2014, by no later than 4pm
on 9 February 2023.
In paragraph 2 of Request No. 34, the Inquiry specified that for the purpose of
this request the definition of a script includes (a) instructions and (b) other
written guidance to Post Office staff on how to handle calls from end-users of
the Horizon IT System. That paragraph also set out (in subparagraphs 2(a) to
2(f).) examples of such materials falling within the scope of Rule 9 Request No.
34.
On page two of Request No. 34, the Inquiry also asked POL not to provide
documents that have already been provided to the Inquiry in response to
previous Rule 9 requests, and to instead list by title and URN (or control
number) any documents that had already provided to the Inquiry.
In total, POL has identified 253 documents which POL considers are responsive
to Request No. 34, copies of which were produced to the Inquiry on 27 February
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2023 and 3 March 2023.
A full list of the searches performed by POL in this context, and the repositories
over which these searches have been conducted, is set out below. All
documents responsive to these searches were subject to manual review (save
for those responsive to search 3 (keywords search) across the email distribution
lists) and relevant documents were produced to the Inquiry.
Mailboxes Searches
Kendra Dickinson Search A (Script search)
Alison Clark Search terms: "script" AND "NBSC"
OR "BSC" OR "Helpline" OR
"Helpdesk" OR "Horizon" OR "call"
Date range: 1 Jan 1999 to 31 Dec
2014 inclusive
Other: N/A
Search B (KBA search)
Search terms: "KBA" OR (knowledge
w/2 base*) OR "Guidance" OR
"instructions" AND "NBSC" OR
"BSC" OR "Helpline" OR "Horizon"
OR "Helpdesk" OR "call"
Date range: 1 Jan 1999 to 31 Dec
2014 inclusive
Other: Exclude documents
responsive to search A (script
search)
Search C (Keywords search)
Search terms: "Call Categorisation
Information" OR (call* w/5 NBSC)
OR (customer w/2 call*) OR (contact
w/2 NBSC) OR (NBSC w/2 actions)
OR ((FAQ* OR "Frequently Asked
Questions") w/10 NBSC) OR
(Advisor w/2 advice) OR "branch
calls" OR (NBSC w/2 advisor*) OR
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("counter colleague" w/10 NBSC)
OR (NBSC w/2 Resol*) OR ("Calls
have been logged" AND NBSC) OR
(NBSC w/5 "what to do") OR (NBSC
w/10 escalat*) OR ("Branch Contacts
NBSC") OR ("advise the branch")
OR ("Branch Support Centre" w/5
FAQ*) OR ("Branch Support Centre"
w/5 guidance) OR ("Branch Support
Centre" w/5 "receiving calls") OR
(handling w/5 calls) OR (difficult w/5
calls)
Date range: 1 Jan 1999 to 31 Dec
2014 inclusive
Other: Exclude documents
responsive to search A (script
search) and search B (KBA search)
Additional Mailboxes Searches
Gayle Peacock Search A (Script search)
Andrew Kenny Search terms: "script" AND "NBSC"
OR "BSC" OR "Helpline" OR
"Helpdesk"
Date range: N/A
Other: N/A
Anne Allaker
Search B (KBA search)
Search terms: "KBA" OR (knowledge
w/2 base*) OR "Guidance" Or
"instructions" AND "NBSC" OR
"BSC" OR "Helpline" OR "Helpdesk"
Date range: N/A
Other: Exclude documents
responsive to search A (script
search)
Search C (Keywords search)
Search terms: "Call Categorisation
Information" OR (call* w/5 NBSC)
OR (customer w/2 call*) OR (contact
w/2 NBSC) OR (NBSC w/2 actions)
OR ((FAQ* OR "Frequently Asked
Questions") w/10 NBSC) OR
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(Advisor w/2 advice) OR "branch
calls" OR (NBSC w/2 advisor*) OR
("counter colleague" w/10 NBSC)
OR (NBSC w/2 Resol*) OR ("Calls
have been logged" AND NBSC) OR
(NBSC w/5 "what to do") OR (NBSC
w/10 escalat*) OR ("Branch Contacts
NBSC") OR ("advise the branch")
OR ("Branch Support Centre" w/5
FAQ*) OR ("Branch Support Centre"
w/5 guidance) OR ("Branch Support
Centre" w/5 "receiving calls") OR
(handling w/5 calls) OR (difficult w/5
calls)
Date range: N/A
Other: Exclude documents
responsive to search A (script
search) and search B (KBA search)
Branch Support Advisor Updates
BSC Coaching
Contact Centre
Knowledge Article Update
Service Support Contact Centres
PSIP — Improving Postmaster
Information
NBSC Knowledge Base Articles
Knowledge Centre
Knowledge Centre Files
Knowledge Centre Refresh
Old Training Material
Branch & Customer Support
Management Team
HM Operations Lead Team
Horizon Queries
Horizon Quick Wins and Transaction
Corrections
Network Support Team
Onboarding Gold Library
SharePoints Searches
Search A (Script search)
Search terms: "script" AND "NBSC"
OR "BSC" OR "Helpline" OR
"Helpdesk"
Date range: N/A
Other: N/A
Search B (KBA search)
Search terms: "KBA" OR (knowledge
w/2 base*) OR "Guidance" Or
"instructions" AND "NBSC" OR "BSC"
OR "Helpline" OR "Helpdesk"
Date range: N/A
Other: Exclude documents responsive
to search A (script search)
Search C (Keywords search)
Search terms: "Call Categorisation
Information" OR (call* w/5 NBSC) OR
(customer w/2 call*) OR (contact w/2
NBSC) OR (NBSC w/2 actions) OR
((FAQ* OR "Frequently Asked
Questions") w/10 NBSC) OR (Advisor
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One Day Basic Transactions:
Distance Learning
Policy
PolicyHub
Postmaster Account Support Team
Horizon Issues Remediation Hub
Learning Design Team — Projects
Branch and Customer Information
Team
w/2 advice) OR "branch calls" OR
(NBSC w/2 advisor*) OR (“counter
colleague" w/10 NBSC) OR (NBSC
w/2 Resol*) OR ("Calls have been
logged" AND NBSC) OR (NBSC w/5
“what to do") OR (NBSC w/10 escalat*)
OR ("Branch Contacts NBSC") OR
("advise the branch") OR ("Branch
Support Centre" w/5 FAQ*) OR
("Branch Support Centre" w/5
guidance) OR ("Branch Support
Centre" w/5 "receiving calls") OR
(handling w/5 calls) OR (difficult w/5
calls)
Date range: N/A
Other: Exclude documents responsive
to search A (script search) and search
B (KBA search)
Emails sent from or to (including
copied):
nbsc.admin.team_
nbsc.customer.relations
NBSCEnquiries ~ GRO
agentadvicesupport
GRO
Searches
Search A (Script search)
Search terms: "script" AND "NBSC"
OR "BSC" OR "Helpline" OR
"Helpdesk" OR "Horizon" OR "call"
“I Date range: N/A
Other: Relativity Native Type: is like
Word OR PDF OR PowerPoint
Search B (KBA search)
Search terms: "KBA" OR (knowledge
w/2 base*) OR "Guidance" Or
"instructions" AND "NBSC" OR
"BSC" OR "Helpline" OR "Horizon"
OR "Helpdesk" OR "call"
Date range: N/A
Other:
- Relativity Native Type: is like
Word OR PDF OR
PowerPoint
- Exclude documents
responsive to search A (script
search)
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Search C (Keywords search)
Search terms: "Call Categorisation
Information" OR (call* w/5 NBSC)
OR (customer w/2 call*) OR (contact
w/2 NBSC) OR (NBSC wi2 actions)
OR ((FAQ* OR "Frequently Asked
Questions") w/10 NBSC) OR
(Advisor w/2 advice) OR "branch
calls" OR (NBSC w/2 advisor*) OR
("counter colleague" w/10 NBSC)
OR (NBSC w/2 Resol*) OR ("Calls
have been logged" AND NBSC) OR
(NBSC w/5 "what to do") OR (NBSC.
w/10 escalat*) OR ("Branch Contacts
NBSC") OR ("advise the branch")
OR ("Branch Support Centre" w/5
FAQ*) OR ("Branch Support Centre"
w/5 guidance) OR ("Branch Support
Centre" w/5 "receiving calls") OR
(handling w/5 calls) OR (difficult w/5
calls)
Date range: N/A
Other:
- Relativity Native Type: is like
Word OR PDF OR
PowerPoint (exclude
Excel/Outlook emails)
- Exclude documents
responsive to search A (script
search) and search B (KBA
search)
In addition to the above searches, POL made a number of further enquiries with
a view to identifying documents of potential relevance to Request No. 34. In
particular:
2.6.1 Oasis documents: POL considered the extent to which relevant hard
copy documents may be held in its various archives (including, for
example, Winchester Oasis). POL conducted searches across its Oasis
indices of hard copy documents and identified 1 file / box that it
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anticipated may contain documents of potential relevance to Request
No. 34. POL made enquiries with Oasis, who confirmed this box was
already at HSF’s premises. HSF conducted a full manual review of this
box. No documents relevant to Request No. 34 were identified for
production.
2.6.2 Shared network drive ('P:Drive’): POL has made a number of
enquiries in relation to the extent to which the P:Drive might hold
material relevant to Request No. 34 (and Request No. 10, in light of
POL being unable to confirm whether WBD's harvesting of the P:Drive
at the time of the Group Litigation was completed).
2.6.3 The full detail of the investigations made by POL into the documents
held on the P:Drive are set out within the statement itself at 64-65. In
total, 156 documents of relevance to one or both of Request No. 10 and
Request No. 34 were produced to the Inquiry on 23 March 2023. These
documents were identified following a manual review of documents
held in the following folders within the P:Drive: (i) "365 Dynamics
Categories ARCHIVE ", (ii) "Core K Base" and (iii) "Dynamics SME".
POL has also harvested and uploaded onto Relativity the following
additional folders from the P:Drive but, following an initial sample review
of the materials held in these folders, concluded that these were
unlikely to contain documents of relevance to Question 16 of Request
No. 10 and/or Request No. 34:
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1 POEX VOICEMAIL RECORDINGS DO NOT DELETE
AEl
Audit folder
Coach Team
Cust
Customer Care Email Log 2017
Customer Care Email Log 2018
Letter Templates
Manual Call Logs
NBSC Call Monitoring 2017
NBSC Call Monitoring 2018
nbsc update folder
BT Cloud Call Scripts.rar
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Annex Ill — 27 February 2023 Production
1. On 16 March 2023 the Inquiry clarified that it ‘does not wish to be provided with
documents that “do not relate in any way to the Horizon IT [system] nor any other
aspect of the issues which the Inquiry is considering’ and that the Inquiry ‘expects
providers of documents to consider the Inquiry’s Terms of Reference and List of
Issues when disclosing documents to the Inquiry.
2. Following receipt of this guidance HSF conducted a reconsideration of the 621
unique documents produced on 27 February 2023' to identify how many (if any) of
the produced documents were not in fact responsive Request No. 10 and/or
Request No. 34 in light of this this clarification.
3. This reconsideration involved manual review of the 621 documents by two Senior
Associates (locums), to divide them into three groups namely:
a. documents which contain substantive information about, or which
substantively relate to, the Horizon IT system and/or other issues relevant
to the Inquiry's Terms of Reference and/or List of Issues ("Relevant
Matters") ("Tier 1 —- Relevant");
b. documents which contain ancillary / peripheral (e.g. passing references)
information about, or which are peripherally related to, Relevant Matters
("Tier 2 — Ancillary"); and
c. documents that neither contain information about, nor relate to, Relevant
Matters ("Tier 3 — Not relevant").
* Namely, the documents produced on 27 February 2023 excluding the 71 ‘examples’ identified in the
production list on that date and the 30 duplicates identified in Annexure A to HSF's letter dated 16 March
2023. POL notes a typographical error in this letter at P4, insofar as it states that Annexure A itemised the
41 documents listed above and have shaded in grey the 34 documents which may be disregarded as
duplicates. The number of duplicates shaded grey in Annexure A was 30.
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4. The results of the reconsideration are reflected in the following table:
Tier 1 — Relevant Tier 2 —- Ancillary Tier 3 — Not Relevant
204 112 305
5. 'Tier 2 — Ancillary' was construed broadly — meaning that documents which might
be capable of relating to the Horizon IT system and/or other aspects of the issues
considered by the Inquiry were included. In order to illustrate the breadth of this
category, I note that they include:
a. General guidance on how to handle calls (e.g. POL-0111677);
b. Guidance on products which include passing references to the use of
Horizon, for example guidance on postage labels produced on Horizon (e.g.
POL-0111696); and
c. Processes to follow in relation to calls about Horizon equipment, but not its
use or operation (e.g. POL-0111979).
6. The documents identified as ‘Tier 2 — Ancillary’ would have been produced
following receipt of the clarification provided on 16 March 2023, in the interests of
construing relevance (as clarified) broadly.
7. The documents identified as ‘Tier 3 — Not Relevant’ would not have been produced
in response to Request No. 10 Question 16 and/or Request No. 34 based on the
clarification provided on 16 March 2023. The documents identified as 'Tier 3 —- Not
Relevant' concern a variety of subject matters which ‘do not relate in any way to
the Horizon IT [system] nor any other aspect of the issues which the Inquiry is
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considering’. The following table divides these documents into 10 general subject
matters and provides examples:
Subject matter
Number of documents
Operational matters — eg changes to opening
hours, unplanned closures, health and safety
16
Stock and Equipment- eg safes, A-Frames,
till DVDs, scales, data coverage, power
cables, telephone lines, name badges and
CareerWear
54
Fleet / mobile outreach branch issues
24
Emergencies — eg hostage situations, bomb
alerts, robbery, hospital admission of SPMR,
theft by public, abusive customers
16
Changes to branch details — eg service cut off
times
Product information — eg customer banking
accounts, travel cards, Identity checking
services, DVLA products, travellers cheques,
DX items, Lottery, local schemes (eg Meals
on Wheels) and Drop & Go
31
Escalations (not related to relevant issues) —
eg processes for escalations to other teams in
POL, suppliers or product owners
47
Complaints (not related to relevant issues) —
eg complaints about other branches,
stationary orders, equipment or products, and
complaints on behalf of customers
67
Miscellaneous subject matter (eg suspicious
parcel reporting, product network
nominations, counterfeit notes, cash deposits
14
10.
Documents which, on reflection, are not
‘scripts’ nor ‘instructions, training or guidance’
relevant to the NBSC helpline — eg network
support admin and ESG notes
32
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