POL00252048
POL00252048
Electronic documents questionnaire
(Civil Procedure Rules Practice Direction 31B)
WARNING: Unless the court makes some other order, the answers given in this document may only be
used for the purposes of the proceedings in which the document is produced unless it has been read to
or by the court or referred to at a hearing which has been held in public or the Court gives permission or
the party who has completed this questionnaire agrees.
Please read the notes at the end of this form before completing the questionnaire
Part 1 — Your disclosure
General Comment
The Claims in this litigation are very broad and the generic pleadings produced by the Claimants so far
provide only limited details on those claims. This litigation therefore has the potential to touch on nearly
all aspects of Post Office's business and the volume of disclosable documents may be enormous.
In this Electronic Disclosure Questionnaire, Post Office has sought to provide a holistic view of the
documents and databases which appear, at this stage, to be potentially relevant to this litigation. It may
be that a further or revised EDQ is required as the issues in dispute are further particularised and
refined, and as more information becomes available.
Post Office does not believe that it would be reasonable or proportionate to disclose all the documents in
all the sources identified below. It proposes, as has been agreed by the Claimants, that following
exchange of the EDQs the parties discuss the purposes and topics for which further disclosure is sought
and seeks to narrow the sources and / or filepaths from which disclosure is provided. The parties can
then also discuss further search criteria, keywords that might be applied to those source documents so
to filter down to those that are truly useful and additional technologies or analytics.
Note on Royal Mail: Post Office and Royal Mail have at all material times been two separate companies
but up to 1 April 2012 Post Office was part of the Royal Mail Group and they had a number of shared IT
systems. After 1 April 2012, the two companies were separated, with Post Office continuing to be
owned by the UK Government and Royal Mail being privatised. Since then the IT systems have also
been separated and Post Office has migrated to using its own systems. Where relevant, this point is
identified below.
Extent of a reasonable search
Date range and custodians
1. What date range do you consider that your searches for Electronic Documents should cover (‘the
date range’)?
In relation to documents which relate to individual Claimants (as per Question 6), disclosure to be
limited to electronic and hard copy documents created between 6 months before the Claimant's
first date of service with Post Office and (a) 6 months after the Claimant's last date of service, or
(b) 6 December 2017 (whichever is earlier).
A number of the Claimants are currently acting as postmasters and thus documents continue to
be generated in relation to them which may be relevant. However, a longstop date of 6
December 2017 has been selected for the practical purpose of having a cut-off date for extracting
data from IT systems into a disclosure review platform. Post Office believes it is reasonable and
proportionate (given the issues with extraction of data explained below) to set a longstop date.
Please see Appendix A to this Electronic Disclosure Questionnaire for the date ranges of each
N264 - Electronic documents questionnaire (Civil Procedure Rules Practice Direction 31B) (10.10) © Crown copyright 2010
4A_37601236_1 41
POL-BSFF-0090111
POL00252048
POL00252048
Claimant.
In relation to "generic" documents, disclosure to be limited to electronic and hard copy
documents created between 1 January 1999 and 6 December 2017.
Attachments to emails which do not fall within the above date ranges should be disclosed where
the parent email falls within the date range.
Identify the custodians or creators of your Electronic Documents whose repositories of
documents you consider should be searched.
Note - Include names of all those who may have or have had custody of disclosable documents,
including secretaries, personal assistants, former employees and/or former participants. It may
be helpful to identify different dates for particular custodians.
Please see Appendix B of this Electronic Disclosure Questionnaire for a list of Key Teams and
Custodians.
As at 1 October 2017, Post Office had 4,965 contracted employees. These work from around
320 different offices and locations, with 461 of Post Office's employees either working from
home or are field-based, meaning that they have no fixed office base. Consequently, Post
Office will have potentially relevant documents spread amongst a significant number of people
and different locations. The list of Key Teams and Custodians at Appendix B is limited to
those teams and individuals who from the generic pleadings appear to be relevant to the
issues in dispute. Post Office considers it reasonable and proportionate to limit its search to
the custodians listed. This may change based on additional information, or if Claimants agree
to limit scope and focus on specific custodians.
Communication
3.
Which forms of electronic communication were in use during the date range (so far as is relevant
to these proceedings)?
Note — Column D - State the geographical location (if known). Consider (at least) servers, desktop PCs,
laptops, notebooks, handheld devices, PDA devices, off-site storage, removable storage media (for
example, CD-ROMs, DVDs, USB drives, memory sticks) and databases
Note - (i) email - Consider all types of e-mail system (for example, Outlook, Lotus Notes, web-based
accounts), whether stored on personal computers, portable devices or in web-based accounts (for example,
Yahoo, Hotmail, Gmail).
Note — (ji) Other - For example, instant messaging, voicemail, VOIP (Voice Over Internet Protocol),
recorded telephone lines, text messaging, audio files, video files.
Communication I In use during Are you Where and on what (a) Are back-ups or
the date range? I searching for type of software/ archives of this
(Yes/No) relevant equipment/ media is communication
documents in I this communication available; and
(vesnoe stored? (b) if so, are you
searching the backups
or archives?
i) E-mail Yes Yes Until c.2012, Post A backup copy of the
Office employees Lotus Notes database
used Lotus Notes. was taken as part of
N264 - Electronic documents questionnaire (Civil Procedure Rules Practice Direction 3B) (10.10)
4A_37601236_1
© Crown copyright 2010
2
2
POL-BSFF-0090111_0001
POL00252048
POL00252048
Microsoft Exchange
was introduced on the
separation of Royal
Mail and Post Office
and when introduced,
Post Office's
employees’ emails
which were stored in
Lotus Notes were
transferred into
Microsoft Exchange.
the migration exercise
and it may be possible,
though not straight
forward, to identify and
export data from this
backup. Post Office
does not believe it
would be necessary to
access this copy due to
the transfer of data into
Microsoft Exchange.
When Microsoft
Exchange was.
introduced Post Office
also introduced email
archiving - initially by
Proofpoint and from
February / March 2016
onwards by Mimecast.
The emails stored in
Proofpoint were
transferred into
Mimecast. These
archives store all
emails sent to or from a
Post Office employee
and emails cannot be
removed from the
archive (unless special
permissions are
granted to do so). Itis
understood that this
archive will hold emails
dating back to 2012
including for Post
Office employees who
no longer work for the
business.
ii) Other
(provide details
for each type)
(a) Skype
Instant
Messaging
(b) SMS
(c) Voicemail
(d) Recorded
calls
(a) No
(b) No
(c) No
(d) Yes
(a) to (c) -— No
(d) Databases
identified in Question
5.
(a) Instant Messages
would be held in each
Custodian's
"Conversation Folder"
in Microsoft Exchange.
There is no archiving.
(b) — (d) The archiving
of documents depends
on the databases in
which they are stored.
A response to this
question is therefore
provided in Question 5.
N264 - Electronic documents questionnaire (Civil Procedure Rules Practice Direction 31B) (10.10)
4A_37601236_1
© Crown copyright 2010
3 3
POL-BSFF-0090111_0002
POL00252048
POL00252048
Electronic Documents
4. Apart from attachments to e-mails, which forms of Electronic Documents were created or stored
by you during the date range?
Note — Column D - State the geographical location (if known). Consider (at least) servers, desktops and
laptops.
Note - Electronic images - For example, .pdf, tif, jpg.
Note ~ Other - For example, PowerPoint or equivalent, specialist documents (such as CAD Drawings)
Document Type I In use during Are you searching I Where and on what I (a) Are back-ups or
the date range? I for relevant type of software/ archives of these
(Yes/No) documents in this I equipment/ media documents available,
category? are these and
(Yes/No) documents?
(b) if so, are you
searching the back-
ups or archives?
Please see Appendix C
Databases of Electronic Documents
5. In the following table identify database systems, including document management systems, used
by you during the date range and which may contain disclosable Electronic Documents.
Name Brief description I Nature of data Are you disclosing Proposals for
held documents held in provision of relevant
this database? documents to or
(Yes/No) access by other
parties to this
litigation
Please see Appendix D for the databases on which Electronic Documents are stored.
Please see Appendix E for information on the databases held by third parties.
For completeness, Appendix F contains information on the storage of hardcopy documents.
N264 - Electronic documents questionnaire (Civil Procedure Rules Practice Direction 3B) (10.10) © Crown copyright 2010
4A_37601236_1 4 4
POL-BSFF-0090111_0003
POL00252048
POL00252048
Method of search
Key words
Note - Where Keyword Searches are used in order to identify irrelevant documents which are to
be excluded from disclosure (for example a confidential name of a client or customer), a general
description of the type of search may be given
6. Do you consider that Keyword Searches should be used Yes O No
as part of the process of determining which Electronic Documents
you should disclose?
If Yes, please provide details of —
(1) the keywords used or to be used (by reference, if applicable, to individual custodians,
creators, repositories, file types and/or date ranges); and
In relation to documents that specifically refer to a Claimant, Post Office proposes to apply
the following key words to identify those documents:
(Claimant's First Name or Claimant's Last Name) AND (Branch Name or Branch Code or
Company Name)) or Mediation Case Number.
For example, a document which included the terms "Alan" or "Bates" and "Craig-y-don" or
"461614" would be identified as a document which is relevant to Alan Bates, as would a
document including the term "M137".
This is subject to the assumption that the number of documents deemed to be keyword
responsive is not disproportionate or unreasonable. These keywords will be considered
further after the data has been extracted, keywords applied and the results discussed with
the Claimants' legal advisors.
As addressed in Womble Bond Dickinson's letter of 24 November 2017, Post Office
proposes that following the exchange of EDQs, the parties discuss the other topics on which
further disclosure is sought and then seek to agree appropriate key words for these topics.
(2) the extent to which the Keyword Searches have been or will be supplemented by a review of
individual documents.
All documents and their family members deemed to be keyword responsive will be
individually reviewed to determine their relevance (and to redact or remove any material
that is legally privileged).
This is subject to the assumption that the number of documents deemed to be keyword
responsive is not disproportionate or unreasonable to be individually reviewed. This will be
determined after the data has been extracted, keywords applied and the results discussed
with the Claimants’ legal advisors.
N264 - Electronic documents questionnaire (Civil Procedure Rules Practice Direction 3B) (10.10) © Crown copyright 2010
4A_37601236_1 5 5
POL-BSFF-0090111_0004
POL00252048
POL00252048
Other types of automated searches
7. Do you consider that automated searches or automated techniques other Yes ONo
than Keyword Searches (for example, concept searches or clustering)
should be used as part of the process of determining which Electronic
Documents you should disclose?
If Yes, please provide details of —
(1) the process(es) used or to be used (by reference, if applicable, to individual custodians,
creators, repositories, file types and/or date ranges);
This will be reviewed once the potentially responsive material has been collected,
indexed and an overview has been obtained as to whether keywords will be
appropriate. Again, that review will include discussion with the Claimants’ legal
advisors.
(2) the extent to which the processes have been or will be supplemented by a review of individual
documents; and
Documents identified as potentially relevant by any searches will be subject to a
review.
(3) how the methodology of automated searches will be made available for consideration by other
parties.
This is something that will be considered in due course once a view has been reached
as to what searches or techniques are appropriate.
8. If the answer to Question 6 or 7 is ‘Yes’, state whether (a) attachments to e-mails (b) compressed
files (c) embedded files and (d) imaged text will respond to your Keyword Searches or other
automated search.
Yes, Post Office proposes that documents which would not be responsive are
converted into an OCR document so as to be responsive to keywords.
Documents which cannot be converted to OCR (such as call recordings), will be
subject to manual review. This is subject to the assumption that the number of
documents is not disproportionate or unreasonable to be individually reviewed. This
will be determined after the data has been extracted, keywords applied and discussion
with the Claimants’ legal advisors.
9. Are you using or intending to use computer software for other purposes in Yes ONo
relation to disclosure?
If Yes, please provide details of the software, processes and methods to be used.
Subject to the issue of proportionality it is envisaged that having collected the data it
will be indexed, non-searchable files containing text will be OCR’d and a fully
searchable database of the material will be prepared — with any documents that
cannot be included being identified.
In addition, it is proposed that a litigation review database (kCura Relativity) will be
used to maximise the efficiency of the review exercise.
N264 - Electronic documents questionnaire (Civil Procedure Rules Practice Direction 3B) (10.10) © Crown copyright 2010
4A_37601236_1 6 6
POL-BSFF-0090111_0005
POL00252048
POL00252048
Potential problems with the extent of search and accessibility of Electronic Documents
Note - See Practice Direction 31B, which refers to the following matters which may be relevant: (a) the
number of documents involved; (b) the nature and complexity of the proceedings; (c) the ease and expense
of retrieval of any particular document; (d) the availability of documents or contents of documents from other
sources; and (e) the significance of any document which is likely to be located during the search.
10. Do any of the sources and/or documents identified in this Electronic Yes ONo
Documents Questionnaire raise questions about the reasonableness of
the search which ought to be taken into account?
If Yes, please give details.
(a) Sharepoint
Post Office has already engaged a third party e-disclosure provider to forensically extract
and preserve potentially relevant documents from SharePoint. This was a considerable
project requiring input from ComputaCenter (Post Office's IT supplier that manages access to
SharePoint), as well as internal input from Post Office's data and information security teams,
IT team and owners of the SharePoint sites. During this extraction a number of issues were
encountered and these may re-occur during future extractions.
. Due to the security permissions being setting up in a granular manner
(enabling access to one area of SharePoint does not enable access to other
areas) there were and may be further issues creating a user account for the
third party e-disclosure provider which enables an appropriate level of access
for documents to be forensically extracted.
. Once access to SharePoint was obtained, Nuix (the collection tool) was
unable to communicate with SharePoint.
. The above matters have now been resolved but similar difficulties may be
faced with further extractions from SharePoint.
(b) Transaction and event data:
As addressed in Womble Bond Dickinson's letter of 22 November 2017 (a copy of which is
enclosed at Appendix G), Post Office has been informed by Fujitsu that there are a vast
number of fields available in the Horizon database which hosts the transaction and event
data and that over time these fields have changed. Post Office therefore proposes it would
be reasonable and proportionate that the data is filtered so that it only includes those fields
which relate to transactions and events which would affect a branch's accounts.
To disclose the unfiltered data would require it to be extracted in a .txt format (rather than in
.xlsx which can be read by Excel) and converted into a readable format. Further, the
unfiltered data would be between 10GB and 1000B of data per branch per month depending
on the size of the branch and the activity in that branch during the month. This compares to
the 1 MB of data per month in the filtered format. The hosting of 400 months of unfiltered
data by Post Office's third party e-discovery partner would cost between £100,000 and £1
million per a month.
The Claimants have not yet responded on this proposal and it will therefore be discussed
between the parties following exchange of the EDQs.
N264 - Electronic documents questionnaire (Civil Procedure Rules Practice Direction 3B) (10.10) © Crown copyright 2010
4A_37601236_1 7 7
POL-BSFF-0090111_0006
POL00252048
POL00252048
(c) Proprietary databases:
A number of the databases used by Post Office are proprietary databases which require
specialist software to review the data in an intelligible format. These databases are often not
set up for mass extraction of data and where it is not possible to extract documents in their
native format, then it is proposed that the documents are (where possible) exported to
commonly used software such as Excel. Further, responsibility for these proprietary
databases during the relevant period has been passed between companies and Post Office is
reliant on the third parties for the transfer of this data between systems and the assistance of
third parties to access this data.
(d) Other:
It is not anticipated that there will be other problems but until the extraction of documents
begins it is impossible to guarantee this.
11. Are any documents which may be disclosable encrypted, password- Yes O No
protected or for other reasons difficult to access, or do you have any
reason to believe that they may be?
If Yes, please state which of the categories identified at Questions 3, 4 and 5 above are affected,
and your proposals for making them accessible.
Note - For example, back-ups, archives, off-site or outsourced document storage, documents created by
former employees, documents stored in other jurisdictions, documents in foreign languages.
Please see Appendix C. A number of the documents contain coding information that, while
often intelligible from the text, would need to be viewed in its native program to see the
intended format.
12. Are you aware of any other points in relation to disclosure of your & Yes ONo
Electronic Documents which require discussion between the parties?
If Yes, please give details.
As addressed above, there is a need to agree search terms, filtering of transaction and event
data, process for exchanging documents and the extent of disclosure which is to be provided
in relation to "generic documents". These matters shall be discussed between the parties
following exchange of EDQs.
Preservation of Electronic Documents
13. Do you have a document retention policy? Yes O.No
If Yes, please give details
The majority of the Post Office's documents are retained for a period of 7 years, however the
specific document retention policies depend on the type of document and team. Please see
Question 5 for further information.
When an employee ceases to be an employee of Post Office, their laptops are re-distributed
within the business. Their emails would remain stored in Mimecast (as explained further in
Question 3) and documents stored in SharePoint.
N264 - Electronic documents questionnaire (Civil Procedure Rules Practice Direction 3B) (10.10) © Crown copyright 2010
4A_37601236_1 8 8
POL-BSFF-0090111_0007
POL00252048
POL00252048
14. Have you given an instruction to preserve Electronic Documents? Yes ONo
If Yes, when did you do so?
Yes, 20 April 2016 and 12 May 2017.
Inspection
15. Subject to re-consideration after receiving the responses of other parties to this Electronic
Documents Questionnaire, (a) in what format and (b) on what media do you intend to provide to
other parties copies of disclosed documents which are or will be available in electronic form?
Please see Appendix H which sets out the Post Office's proposals made to the Claimants on
14 November 2017. This matter will be discussed between the parties following the exchange
of EDQs.
16. Subject to re-consideration after receiving the responses of other parties to this Electronic
Documents Questionnaire, do you intend to provide other parties with Disclosure Data
electronically?
If Yes, in what format and on what media?
See Question 15, above. The format and media / method of delivery will be agreed with the
other party and could involve USB stick or hard drive or sftp transfer - depending on volumes
and what is agreed.
17. Insofar as you have available or will have available searchable OCR Yes O.No
versions of Electronic Documents, do you intend to provide the
searchable OCR version to other parties?
Note - There is no requirement that you should obtain OCR versions of documents, and this question is
directed only to OCR versions which you have available or expect to have available to you. If you do provide
OCR versions to another party, they will be provided by you on an ‘as is’ basis, with no assurance to the
other party that the OCR versions are complete or accurate. You may wish to exclude provision of OCR
versions of documents which have been redacted.
If No, why not?
N/A
N264 - Electronic documents questionnaire (Civil Procedure Rules Practice Direction 3B) (10.10) © Crown copyright 2010
4A_37601236_1 9 9
POL-BSFF-0090111_0008
POL00252048
POL00252048
Part 2 - The disclosure of other parties
The extent and content of their search
18. Do you at this stage have any proposals about the date ranges which Yes ONo
should be searched by other parties to the proceedings?
If Yes, please provide details.
Same as Question 1.
19. Do you at this stage have any proposals about the custodians or creators Yes ONo
whose repositories of documents should be searched for disclosable
documents by other parties to the proceedings?
If Yes, please provide details.
Note - Include names of all those who may have or have had custody of disclosable documents, including
secretaries, personal assistants, former employees and/or former participants. It may be helpful to identify
different dates for particular custodians.
As raised with the Claimants on 30 May 2017, Post Office proposes that the following
custodians should be within scope for searching:
(a) Claimants;
(b) Claimant's accountants / financial advisors;
(c) Claimant's previous lawyers;
(d) Claimant's insolvency practitioners (where applicable);
(e) Claimant's estate agents (where Claimant is seeking to claim loss of investment)
(f) HMRC / Claimant's tax advisors;
(g) Claimant's medical advisors (where Claimant is seeking to claim personal injury);
(h) other business advisors;
(0) Claimant's branch managers or assistants; and
0) Claimant's family member (where Claimant is seeking to claim for losses caused to
them).
N264 - Electronic documents questionnaire (Civil Procedure Rules Practice Direction 3B) (10.10) © Crown copyright 2010
4A_37601236_1 10 610
POL-BSFF-0090111_0009
POL00252048
POL00252048
20. Do you consider that the other party(ies) should disclose all available Yes ONo
Metadata attaching to any documents?
If Yes, please provide details of the documents or categories of documents.
Note - ‘Metadata’ is information about the document or file which is recorded in the computer, such as the
date and time of creation or modification of a word-processing file, or the author and the date and time of
sending of an e-mail. The question is directed to the more extensive Metadata which may be relevant where
for example authenticity is disputed.
Disclosure is sought of all available files in their native format together with a load file indexing
that material and holding the key metadata fields — in the same way as is contemplated for
disclosure by Post Office as outlined in our response to Question 15 above.
Proposals for the method to be adopted for their searches
21. Do you at this stage have any proposals about the Keyword Searches, or Yes ONo
other automated searches, which should be applied by other parties to
their document sets?
If Yes, please provide details.
As stated at Question 12 above, this is something that will need to be discussed and agreed in
due course.
Inspection
22. Subject to re-consideration after receiving the responses of other parties to this Electronic
Documents Questionnaire, (a) in what format and (b) on what media do you wish to receive
copies of disclosed documents which are or will be available in electronic form?
(a) The format in which the documents were created.
(b) The media / method of delivery will be agreed with the other party and could involve USB
stick or hard drive or sftp transfer - depending on volumes and what is agreed.
23. Subject to re-consideration after receiving the responses of other parties Yes O No
to this Electronic Documents Questionnaire, do you wish to receive
Disclosure Data electronically?
If Yes, in what format and on what media?
See response to Question 22 above.
N264 - Electronic documents questionnaire (Civil Procedure Rules Practice Direction 3B) (10.10) © Crown copyright 2010
4A_37601236_1 nu 44
POL-BSFF-0090111_0010
POL00252048
POL00252048
STATEMENT OF TRUTH
The Defendant believes that the facts stated in the answers to this Electronic Documents Questionnaire
are true
lam duly authorised by the Defendant to sign this statement
Full name: Andrew Paul Parsons
Name of legal representative's firm: Womble Bond Dickinson
ANDREW PARSONS
Signed
Position or office held Partner
(if signing on behalf of firm or company)
Date: 6 December 2017
N264 - Electronic documents questionnaire (Civil Procedure Rules Practice Direction 31B) (10.10) © Crown copyright 2010
4A_37601236_1 2 12
POL-BSFF-0090111_0011
POL00252048
POL00252048
Claim No: HQ16X01238 and HQ17X02637
IN THE HIGH COURT OF JUSTICE
QUEEN'S BENCH DIVISION
THE POST OFFICE GROUP LITIGATION
BETWEEN:
ALAN BATES & OTHERS
Claimant
AND
POST OFFICE LIMITED
Defendant
APPENDIX A
Please refer to the spreadsheets provided with the EDQ to Freeths on 6
December 2017
13
POL-BSFF-0090111_0012
Appendix B
Post Office's proposals for Post Office's Key Custodians
POL00252048
POL00252048
Agent Accounting Team
Handles shortfalls in the
branches of current
postmasters.
Team of approx. 10.
Dawn Phillips (Team Leader — Agent Accounting
and Santander Banking)
November 2016, held
other similar roles for
Post Office since 15 April
2013
Current
Dawn Wall (Team Leader — Agent Accounting and
Cash Control, Personal Banking & Stock)
06 June 1994
Current (changed role
in November 2016)
Team inbox:
agent.accounting.tean,
Former Agent Debt Handles shortfalls in the Michelle Stevens (Team Leader) 05 February 1996 Current
branches of former
postmasters. Jenny Smith 04 July 1994 Current
Team inbox:
Team of approx. 5.
Formeragent.account
NT Programme and Policy I Team responsible for Peter Johnson (Head of Policy and Strategy January 2016, held other I Current
developing the strategy and Network Transformation) similar roles for Post
policies relating to Network Office since February
Transformation and the 1986
associated contracts.
Part of wider NT team of Ramantha Benton (Network Transformation Policy I April 2013 Current
approx. 600 individuals. anager)
Approx. 10 members of this
team.
Contract and Policy Team responsible for Paul Inwood (Contracts and Policy Development 1 April 2010, held various I Current
14
POL-BSFF-0090111_0013
POL00252048
POL00252048
Development
developing contracts and
policies which cover the
lifecycle of a postmaster.
Manager)
similar roles with Post
Office since 1 April 1986
10. Team of approx. 12. Stewart Barclay (Postmaster Contracts Policy 41 January 2003, held Current
Advisor) various similar roles for
Post Office since 07
February 1986
"1. Scheduling & Admin Team responsible for the Lee Heil (Team Leader) August 2008 Current
72 training of postmasters.
° Donna Squires (Admin Advisor) 2003 Current
8. Team of approx. 12. Paul O'Leary (Team Leader) June 2012 Current
14. Sandra McBride 6 April 1986 September 2017
15. Sue Richardson (Network Operations Support 5 December 1988 December 2017
Manager)
16. Jackie Newton (Head of Learning) 28 August 1984 Current
17. Team inbox: .
network.support.admin.team
18. Contracts Team manages the John Breeden (Head of Agency Contracts 1 April 2005, held similar I Current
contractual relationship Deployment, previously Agent Contracts roles with Post Office
between Post Office and Deployment Manager North) since 6 January 1997
75 postmasters.
. Team of approx. 40. Craig Tuthill (Head of Agency Contracts 04 February 1980 31 March 2017
Deployment)
20. Lin Norbury (Agent Contracts Deployment 43 August 1971 31 July 2017
Manager South)
21. Keith Bridges (Agent Contracts Deployment 1 August 2017 Current
15
POL-BSFF-0090111_0014
POL00252048
POL00252048
Manager North)
22. 10 Contract Advisors Various between 1999 Various between
and 2017 1999 and 2017
a NBSC Team responsible for the Kendra Dickinson (Senior Service and February 2016, been Current
main helpline contacted by Performance Manager) employed by Post Office
postmasters. since c.1986 with various
Team of approx. 100 similar roles
24. individuals. Gayle Peacock (Head of Branch Customer November 2015, been Current
Services) employed by Post Office
in various roles since
November 2001
25. Dean Whitehead (Workforce Manager) February 2014 Current
26. Nigel Davies (Training and Quality Manager) February 2014 Current
27. 5 Team Leaders Various Various
26. Branch Support Services Worked alongside Contract Andrew Kenny 29 April 2002 Current
Advisors and NBSC.
29. I (2006 to 2016) Anne Allaker (Change and Improvement Manager, I 29 July 1991 April 2017
Branch and Customer Support)
30. Team inbox:
Branch.support.teami and
branch.support.servicés:téai
31. Security Operations Team handles security Sharron Logan July 2007 Current
32. I issues and investigations into
* fraudulent activity. Helen Dickinson 2000 Current
Te f . 20.
38. eam of approx, John Scott 22 February 1993 30 September 2016
16
POL-BSFF-0090111_0015
POL00252048
POL00252048
34. Amy Quirk (Head of Security Operations and 12 January 2015 4 April 2017
Intelligence)
35. Mark Raymond (Head of Security Operations) April 2017, employed by I Current
Post Office in other
similar roles since
January 2016
36. Chris Knight April 2004 Current
37. Support Services Assists postmasters and Post I Kath Alexander (SSRT and Mediation Case August 2013, employed Current
Resolution Office to resolve issues Review Manager) by Post Office in other
which have arisen in roles since June 1983
38 branches.
. Shirley Hailstones (SSRT and Mediation Case September 2013, Current
Team of approx. 10. Review Manager) employed by Post Office
in other roles since June
1988
38. 8 SSRT Advisors Various Various
40. Team inbox:
support.services.resoluti
bal Cash Management, Fraud I Team handles branch Andrew Keighley (Retail Cash Manager) November 1983 Current
ro) Analysis and Branch requests for cash and carries
* Standards out fraud and branch Doug Brown (Senior Retail Cash Manager) January 1985 Current
rr) standards analysis.
. Rebecca Porch (Team Manager) October 2002 Current
44. Kelly Bloodworth (Team Manager) August 2016 Current
45. Kim Abbotts (Head of Fraud Analysis and Branch April 2017, employed by Current
Standards) Post Office in other
similar roles since March
17
POL-BSFF-0090111_0016
POL00252048
POL00252048
1987
46. Sally Smith (Head of Financial Crime) October 2016, employed I Current
by Post Office in other
similar roles since
September 2011
47. Financial Services Centre I The individuals named are Alison Bolsover (Debt Recovery Manager) 29 April 1985 Current
rr Team Leaders for the areas
. within the Financial Services I Lorraine Garvey (FSC Enquires Manager) 05 March 2001 31 December 2016
46 Centre which may relate to
. the Group Action. Paul Smith (Ops Support Manager) 24 June 1996 Current
50 The Financial Services
. Centre is made up of approx. I Gillian Hoyland (Ops Support Manager) 24 February 1986 Current
51 100 people.
. Tracey Mather (Cheques & Moneygram Team 26 January 1987 Current
Leader)
52. Allison Walton (Lottery & Cards Team Manager) 12 June 1995 Current
58. Kay Wilson (Settlement Manager) 20 January 1997 Current
54. Jackie Whitman (Settlements Team Leader) 01 August 1994 Current
56. Tracy Middleton (Automated Payment Enquires 11 January 1988 Current
Manager & Stock Team Leader)
56. Carol King (Accounts Payable Team Leader) 24 March 1986 Current
Mark Wood (Risk & Compliance Manager, TBC Current
Moneygram Team)
57. Agent Application Team manages the Sarah Rimmer (Agent Application Manger) May 2004 May 2017
58 Processing application process from
° initial applications, interviews I Sheinaze Aboobaqar (Agent Application Manger) May 2017 Current
18
POL-BSFF-0090111_0017
POL00252048
POL00252048
and issuing of contracts.
Team of approx. 15.
59. Network Operations Team assist to arrange Colette McAteer (Network Operations Support 04 September 2000 Current
further training for Manager)
60 postmasters and broader
. support which may be Theresa Raybould (Team Leader) 09 April 2001 March 2017
required.
81. John B Jenkinson (Agent Services Manager) TBC TBC
62. IT Dave King (Senior Technical Security Assurance 1996 Current
Manager)
83. Paula Jenner (Head of IT Service for Finance and I 21 June 1993 Current
Operations)
84, HR Naomi McKay (Support Service Team Manager, 10 March 2014 Current
previously HR Advisor)
85. Chris Howard (Agency Remuneration 07 July 1980 Current
Development Manager)
86. Recruitment Work alongside the Agent Jo Stammers 09 February 2004 Current
67 Application Team.
. Hector Campbell 17 December 1979 31 July 2017
88. Tracey Wilkes (Centre Manager) 06 November 1995 Current
69. Sales Capability, Branch Provide postmasters with Craig Perrins (Head) 15 August 2005 Current
70 Standards & Network sale support and analsyis of
. Conformance sales. Team inbox
Team of approx. 45.
m1. Relationship Manager Worked alongside the Andrew Winn 22 November 1996 30 June 2016
Contract Advisors to resolve
19
POL-BSFF-0090111_0018
POL00252048
POL00252048
branch issues.
72. Mediation Scheme Team set up to manage the Mark Underwood (Head of Portfolio: Legal, Risk & I April 2017, joined Post Current
Mediation Scheme. Governance) Office in September
2014
#3. Patrick Bourke (Corporate Affairs Director) April 2017, joined Post Current
Office in September
2014
v4. Angela Van den Bogerd (People & Change 01 April 1985 Current
Director)
#6. Tom Wechsler (Government and Payments. April 2007, joined Post Current
Services Director) Office in September
2014
76. Belinda Crowe (Complaint Review & Mediation 01 January 2014 31 March 2015
Scheme Programme Director)
a. David Oliver (Complaint Review & Mediation TBC November 2014
Scheme Programme Manager)
78. Legal (documents relating Jarnail Singh 18 December 1989 06 March 2015
76 to these custodians will not
. be extracted due to Rodric Williams 20 August 2012 Current
30 privilege)
. Jane Mcleod (Group Legal, Risk & Governance TBC Current
Director)
81. Group Communications, Responsible for Jonathan Knox (Production & Channels Manager, 26 June 2006 Current
Brand & Corporate Affairs: I communications with Internal Communications)
2 Communications Delivery branches.
° Mark Horne (Production Advisor, Internal 15 September 1998 Current
Communications & Engagement)
20
POL-BSFF-0090111_0019
POL00252048
POL00252048
APPENDIX C
Electronic Documents
Document Type In use IAre you searching for I Where and on what type of software / I (a) Are back-ups or archives of these
during date I relevant documents in this I equipment / media are these I documents available, and
range? category? documents? (b) if so, are you searching the back-
ups and archives?
Microsoft Word Yes Yes - depending on agreement I Documents which are stored in the I The archiving of documents depends on
between Post Office and I locations identified in Question 5. the databases in which they are stored.
Claimants on data sources and A response is therefore provided in
filetypes to be searched for Question 5.
disclosure.
Microsoft Excel Yes Yes - depending on agreement I As above As above
between Post Office and
Claimants on data sources and
filetypes to be searched for
disclosure.
Microsoft PowerPoint I Yes Yes - depending on agreement I As above As above
Presentation between Post Office and
Claimants on data sources and
filetypes to be searched for
disclosure.
Microsoft Access Database I Yes Yes - depending on agreement I As above As above
between Post Office and
Claimants on data sources and
filetypes to be searched for
disclosure.
Microsoft Project Yes Yes - depending on agreement I As above As above
between Post Office and
21
POL-BSFF-0090111_0020
POL00252048
POL00252048
Claimants on data sources and
filetypes to be searched for
disclosure.
Microsoft MapPoint
Yes
No - Would require a copy of
MS MapPoint to review these
documents which was
discontinued in 2014.
As above
As above
Microsoft Publisher
Yes
Yes - depending on agreement
between Post Office and
Claimants on data sources and
filetypes to be searched for
disclosure.
As above
As above
Microsoft Works Documents
Yes
Yes - depending on agreement
between Post Office and
Claimants on data sources and
filetypes to be searched for
disclosure.
As above
As above
Microsoft XPS Document
Yes
Yes - depending on agreement
between Post Office and
Claimants on data sources and
filetypes to be searched for
disclosure.
As above
As above
Compuserve GIF
Portable Network Graphics
Format
JPEG
Post Script
Yes
No - From a review of the
documents which have been
extracted from Post Office to
date, documents of this type
have predominately been
attachments to emails which
contain image files of the email
footer (i.e. Post Office's logo).
As above
As above.
Calendar items
Including: Microsoft Outlook
Schedule, Microsoft Outlook
Appointment, iCalender
Entry, vCalendar
Yes
Yes - depending on agreement
between Post Office and
Claimants on data sources and
filetypes to be searched for
disclosure.
As above
As above
22
POL-BSFF-0090111_0021
POL00252048
POL00252048
Extensible Markup
Language (XML)
MHTML.
Plain text (UTF-8 encoded
Text)
Ini Style Configuration File
Microsoft OLE2 File
Yes
Yes - depending on agreement
between Post Office and
Claimants on data sources and
filetypes to be searched for
disclosure.
Note — these files typically
contain coding information that,
while often intelligible from the
text, would need to be viewed in
its native program to see the
intended format. This may
require proprietary software.
As above
As above.
HTML Documents
Yes
Yes - depending on agreement
between Post Office and
Claimants on data sources and
filetypes to be searched for
disclosure.
As above
As above
Microsoft Outlook Email
Yes
Yes - depending on agreement
between Post Office and
Claimants on data sources and
filetypes to be searched for
disclosure.
As above
As above
Microsoft Outlook Contact
Yes
No
As above
As above.
Microsoft Outlook Sticky
Note
Yes
Yes - depending on agreement
between Post Office and
Claimants on data sources and
filetypes to be searched for
disclosure.
As above
As above
Rich Text Format
Yes
Yes - depending on agreement
between Post Office and
Claimants on data sources and
filetypes to be searched for
disclosure.
As above
As above.
Windows Bitmap Graphic
Yes
No
As above
As above
23
POL-BSFF-0090111_0022
POL00252048
POL00252048
Media files Yes Yes - depending on agreement I As above As above
between Post Office and
Including: Windows Sound, Claimants on data sources and
Windows Media Audio and filetypes to be searched for
Video files, MPEG Audio disclosure.
and Video files, QuickTime
Multimedia File, Resource
Interchange File Format,
Microsoft Advanced
Systems Format Multimedia
Fil
Microsoft Windows Metafile I Yes Yes - depending on agreement I As above As above
between Post Office and
Claimants on data sources and
filetypes to be searched for
disclosure.
Microsoft Visio Yes Yes - depending on agreement I As above As Above.
between Post Office and
Claimants on data sources and
filetypes to be searched for
disclosure.
Internet Mail Message Yes Yes - depending on agreement I As above As above
between Post Office and
Claimants on data sources and
filetypes to be searched for
disclosure.
Open Office Yes Yes - depending on agreement I As above As above
between Post Office and
Claimants on data sources and
filetypes to be searched for
disclosure.
Lotus Documents. Yes Yes - depending on agreement I As above As above
between Post Office and
Claimants on data sources and
filetypes to be searched for
disclosure.
24
POL-BSFF-0090111_0023
APPENDIX D
Databases of Electronic Documents
POL00252048
POL00252048
POST OFFICE'S DATABASES
Name Brief description Nature of data held Are you disclosing documents held I Proposals for provision of relevant
in this database (Yes/No) documents to or access by other
Parties to this litigation
Lotus Microsoft Exchange is Post Office's I As set out in Question 4. Yes — subject to reasonable and I Make available in native format (.msg
Notes and I principal email software used by all proportionate search parameters I file).
Microsoft employees. Microsoft Exchange was being agreed between the parties
Exchange introduced by Post Office in c.2012. following exchange of EDQs. Where documents have redacted,
documents to be made available in PDF
Prior to Microsoft Exchange, Post Office or tiff format.
employees within Royal Mail used Lotus
Notes.
Please see Question 3 for an explanation
of archiving.
It is anticipated that an average user can
be expected to send and receive 31,000
emails a year. Extracting the accounts of
all the Key Custodians for one year
would therefore capture around
2,511,000 emails (plus attachments).
SharePoint I Web-based Microsoft platform on which I As set out in Question 4. Yes - the workspaces to be I Either make available in native format or
documents are held in shared
workspaces. SharePoint was introduced
by Post Office in 2012 and holds records
dating back to then. If a document is
deleted from SharePoint then these
documents are potentially restorable for
approximately 60 days, following which
they are permanently deleted.
considered for disclosure are to be
discussed and will need to be agreed
between the parties _ following
exchange of EDQs.
where it is not possible to extract
documents in their native format, then
export to an alternative form as
appropriate.
POL-BSFF-009011
25
1_0024
POL00252048
252048
POLOO:
The entirety of SharePoint is approx. 1.5
TB of data and a list of the workspaces
within Post Office's SharePoint is
enclosed at the end of this Appendix.
E-Filing
Cabinets
From around 2004 to the introduction of
SharePoint, Post Office used E-Filing
Cabinets within Lotus Notes for the
storage of electronic documents.
The E-Filing Cabinets were on a server
hosted by Royal Mail. Following Post
Office's separation from Royal Mail on 1
April 2012, access to the E-Filing
Cabinets was lost.
On 28 June 2017, Royal Mail provided
Post Office with a copy of the E-Filing
Cabinets. However, this copy is not
complete with, for example, some
attachments to emails and _ files
embedded in other documents having
been lost.
As set out in Question 4
Yes — to the extent possible, and
subject to reasonable and
proportionate search parameters
being agreed between the parties
following exchange of EDQs.
Either make available in native format or
where it is not possible to extract
documents in their native format, then
export to an alternative form as
appropriate.
Laptops
and One
Drive
Since March 2016, Post Office has used
a cloud based platform called One Drive.
One Drive synchronises_ with the
documents held in the "My Documents"
folder for a user. If a document is
deleted from either the "My Documents"
folder or from One Drive then these
documents are potentially restorable for
approximately 60 days, following which
they are permanently deleted.
Prior to One Drive, Post Office's
employees stored their documents in
shared network locations on a windows
servers. When Post Office transitioned
As set out in Question 4.
Yes — to the extent possible, subject to
reasonable and proportionate search
parameters being agreed between the
parties following exchange of EDQs.
Either make available in native format or
where it is not possible to extract
documents in their native format, then
export to an alternative form as
appropriate.
POL-BSFF-009011
26
1_0025
POL00252048
POL00252048
from the shared network locations to One
Drive, each employee was responsible
for transferring their documents into One
Drive. Post Office still has the servers
which hold the shared network locations
(including for Post Office employees who
have left the business) and will be kept
by Post Office for the next 7 years.
There is 25 TBs of data stored in the
shared network locations.
Network Alongside SharePoint some teams use I As set out in Question 4. Yes - subject to reasonable and I Either make available in native format or
Drives shared networks drives. proportionate search parameters I where it is not possible to extract
being agreed between the parties I documents in their native format, then
For example: following exchange of EDQs. export to an alternative form as
appropriate.
(i) the Security and Legal teams store
documents in the L: Drive. In July 2015,
the data was collected from these drives
and amounts to 201,187 documents.
(ii) the Remuneration and Application
teams store documents in the T: Drive.
(iii) NBSC store documents in the
N:Drive.
Horizon Transaction and event data As set out in Question 4. Transaction and event data Either make available in native format or
Transaction data is the line-by-line record
of each transaction processed in a
branch. Event data records events on
Horizon such as logging on and off,
printing certain reports, etc. In Horizon
Online (i.e. since 2010) this data is input
on terminals in a branch and then
transmitted to and stored in central data
centres.
Transaction and event data is held in the
To retrieve all transaction and event
data for all of the Claimants will be a
considerable undertaking. Fujitsu
have informed Post Office that to
extract one month of data for a branch
takes 1 % hours. To extract a years’
worth of data for all Claimants would
take approx. 10,000 man hours. This
is a technical limitation on the system.
where it is not possible to extract
documents in their native format, then
export to an alternative form as
appropriate.
POL-BSFF-009011
27
1_0026
POL00252048
POL00252048
central data centres for a period of seven
years. After 7 years, the data is usually
deleted at regular intervals. In October
2014, as part of the Mediation Scheme,
Post Office instructed Fujitsu to stop
deleting transaction and event data. Post
Office understand that Fujitsu currently
holds transaction and event data for all
branches dating back to October 2007.
Counter logs
Post Office understand from __ its
discussions with Fujitsu that there are a
number of logs held on the terminals and
not stored in the data centre. The two
which may, depending on the
circumstances, be of relevance are:
. The "postofficecounterlog" which
contains data concerning
interactions between the terminal
and the PiNpad, rateboard and
printer; information messages
from the Counter Business
Application (e.g. identifying
button presses and messages
which appear on the terminal
screen); and the building of
reference data for use by the
Horizon application.
. The "messagelog" which contains
information about messages sent
from the counter to the data
centre and the responses
received from the data centre.
The logs are held on a terminal for a
period of 30 days, following which they
are overwritten. Fujitsu can extract the
Disclosure of transaction and event
data will be given, but will need to
focussed to particular Claimants and
dates in order to be provided in a
timely manner.
Counter logs
No.
On 28 September 2017, Womble
Bond Dickinson made proposals to
Freeths on the preservation of the
relevant counter logs. This proposal
explained that to extract the logs for all
Claimants who are live postmasters
(approx. 140) would take around 280
hours every month (since process
would need to be run every 30 days
due to the over writing of the data).
This would be unreasonable and
disproportionate.
Post Office therefore proposed that if
a Claimant believes they have
experienced a technical issue with
Horizon, and if the NBSC and HSD
have been unable to resolve the issue
to the satisfaction of the Claimant,
they may request the counter log from
Fujitsu.
28
POL-BSFF-0090111_0027
POL00252048
POL00252048
logs from a terminal through a manual
process which takes approximately two
hours.
There are other logs on the terminal,
such as a log which shows how much
memory is in use and logs which relate to
the windows operating system. However,
Post Office does not believe that these
are relevant.
POLSAP POLSAP is a database which records I As set out in Question 4. Yes Either make available in native format or
financial information and accounting where it is not possible to extract
ledgers. It has been in use since 2005. POLSAP is a database provided on I documents in their native format, then
licence by SAP. To extract data,I export to an alternative form as
Data in POL SAP which is more than 7 reports must be run to produce I appropriate.
years old is archived. Post Office information in a format that can be
understands that no data should have understood and interpreted. Alternatively, it may be that the Claimant
been deleted from this archive. can inspect POLSAP on site at Post
Following exchange of EDQs the I Office.
In March 2018, Post Office will stop using parties can discuss the reports to be
POLSAP and move to Core Finance and run.
steps have been taken to preserve
POLSAP when it is taken offline.
As at July 2017, POLSAP contained 6.5
TB of live data and 17.7 TB of archived
data.
Core Database within which the Financial I As set out in Question 4. Yes Either make available in native format or
Finance Services Centre records _ financial where it is not possible to extract
information — similar to POLSAP..
From around 1 September 2014 certain
teams began using Core Finance instead
of POLSAP. Core Finance does not
archive data and all data should be
available on the system.
As_at September 2017, Core Finance
Similar to POLSAP, to extract data
from Core Finance, reports must be
run to produce information in a format
that can be understood and
interpreted.
Following exchange of EDQs the
parties can discuss the reports to be
fun.
documents in their native format, then
export to an alternative form as
appropriate.
Alternatively, it may be that the Claimant
can inspect Core Finance on site at Post
Office.
POL-BSFF-009011
29
1_0028
POL00252048
POL00252048
contained 1 TB of data.
HRSAP
Database within which information is held
on Post Office's employees, postmasters
and assistants.
Records date back to 2003 wnen HRSAP
was _ introduced. HRSAP does not
archive data and all data should be
available on the system.
HRSAP is due to be replaced in February
2018. Post Office is putting in place
measures to ensure that this data is
preserved.
As set out in Question 4.
Yes
HRSAP is a database provided on
licence by SAP. To extract data,
reports must be run to produce
information in a format that can be
understood and interpreted.
Following exchange of EDQs, the
parties can discuss the reports to be
run
Either make available in native format or
where it is not possible to extract
documents in their native format, then
export to an alternative form as
appropriate.
Remedy
Call centre software used for logging
calls to the NBSC between 2000 and
2014. When Post Office switched from
Remedy to Dynamics the majority of call
logs from Remedy were loaded into an
Access database.
The logs describe briefly the nature of the
question and the answer given.
As set out in Question 4.
Yes — subject to reasonable and
proportionate search parameters
being agreed between the parties
following exchange of EDQs.
Either make available in native format or
where it is not possible to extract
documents in their native format, then
export to an alternative form as
appropriate.
Dynamics
Call centre software used for logging
calls to the NBSC between 2014 to
present.
The logs describe briefly the nature of the
question, the answer given and where
appropriate refer to an article in the
Knowledge Base.
Between 2014 and 3 November 2017 the
NBSC have been recording calls for
training and monitoring purposes. Call
recordings are deleted after 3 months
(save where copied into SharePoint).
As set out in Question 4.
Yes — subject to reasonable and
proportionate search parameters
being agreed between the parties
following exchange of EDQs.
Either make available in native format or
where it is not possible to extract
documents in their native format, then
export to an alternative form as
appropriate.
POL-BSFF-009011
30
1_0029
POL00252048
POL00252048
Post Office is in the process of changing
the call recording provider and as such
the recordings were temporarily
suspended on 4 November 2017.
Since 2014, Dynamics has also been
used by the training team to keep records
of postmaster's training. The previous
records were stored in a no longer active
Access database which has been
exported into Excel for preservation.
Knowledge I Stores the articles referred to by the I As set out in Question 4. Yes - subject to reasonable and I Either make available in native format or
Base NBSC's advisors. There are currently proportionate search parameters I where it is not possible to extract
approx. 5,000 articles within Knowledge being agreed between the parties I documents in their native format, then
Base. Historic articles have not been following exchange of EDQs. export to an alternative form as
archived. This database is run from appropriate.
SharePoint.
Credence Management information tool that I As set out in Question 4. No - Credence processes data which I N/A
provides, for example, the value, dates is held in other databases, for
and times of transactions. Credence was example the transaction and event
introduced in c.2009 and provides access data available through Horizon, data
to the previous 24 months of data. from HRSAP, etc.
HORice Tool used by Security team during I As per Question 4. No - Horizon feeds certain transaction I N/A
investigations. HORice provides access and event data into HORice.
to previous 6 months of transaction and
event data.
iMAP Database which contains _ branch I As per Question 4. Yes - subject to reasonable and I Either make available in native format or
information used by the Network Design proportionate search parameters I where it is not possible to extract
and Analysis team. being agreed between the parties I documents in their native format, then
following exchange of EDQs. export to an alternative form as
appropriate.
Network Includes dates of service of Post Office's I As per Question 4. Yes — subject to reasonable and I Either make available in native format or
Reinvention I agents. proportionate search parameters I where it is not possible to extract
Database being agreed between the parties I documents in their native format, then
POL-BSFF-009011
31
1_0030
POL00252048
POL00252048
following exchange of EDQs. export to an alternative form as
appropriate.
Huddle Huddle is a project management and I As per Question 4. Yes -— subject to reasonable and I Make available in native format.
document storage platform that was used proportionate search parameters
throughout the Complaint Review and being agreed between the parties
Mediation Scheme. following exchange of EDQs.
EASE / I Prior to 2010, records of training were I As per Question 4. Yes — subject to reasonable and I Either make available in native format or
Knowledge I held in the E-Filing Cabinets. proportionate search parameters I where it is not possible to extract
Centre being agreed between the parties I documents in their native format, then
After 2010, the training team and audit following exchange of EDQs. export to an alternative form as
teams combined to make the field team. appropriate.
Their records were then held on a
platform called EASE. EASE is also
used to store policy documents. Post
Office is due to replace EASE with
Knowledge Centre. In anticipation of the
replacement of EASE, most documents
have been moved to the new platform.
Success Success Factors is a cloud based I As per Question 4. Yes — subject to reasonable and I Either make available in native format or
Factors and I management platform provided by SAP. proportionate search parameters I where it is not possible to extract
Tortora used by the Post Office Learning being agreed between the parties I documents in their native format, then
LMS Academy. It is an online portal to provide following exchange of EDQs. export to an alternative form as
training and resources to postmasters. appropriate.
Success Factors was introduced at the
end of 2016.
Similarly, Tortora is an online learning
management system used the training
team.
Combat Web-based platform used by the Sale I As per Question 4. Yes — subject to reasonable and I Either make available in native format or
Capability, Branch Standards and
Network Conformance Team.
proportionate search parameters
being agreed between the parties
following exchange of EDQs.
where it is not possible to extract
documents in their native format, then
export to an alternative form as
appropriate.
POL-BSFF-009011
32
1_0031
POL00252048
POL00252048
LIST OF SHAREPOINT WORKSPACES
Size (in MB) I Url Title
6 https://poluk.sharepoint.com/sites/app_catalog POL APP CATALOG
2163 https://poluk.sharepoint.com/sites/A908 NTProjects
272 https://poluk.sharepoint.com/sites/A1098 Glasgow Team Site
1 https://poluk.sharepoint.com/sites/Area1Team51 Area 1 Team
556 https://poluk.sharepoint.com/sites/Robotics Robotics
17 https://poluk.sharepoint.com/sites/SampleTeam Sample Team
1 https://poluk.sharepoint.com/sites/121s 121's
1 https://poluk.sharepoint.com/sites/Area7Team5S7 Area 7 Team
70840 https://poluk.sharepoint.com/sites/A853_ HRSC Bolton
1001 https://poluk.sharepoint.com/portals/Post-Office Post Office
1 https://poluk.sharepoint.com/sites/Area3Team80 Area 3 Team
31096 https://poluk.sharepoint.com/sites/POA006 Network & Sales
1 https://poluk.sharepoint.com/portals/ClO clo
149 https://poluk.sharepoint.com/sites/Training Training
82 https://poluk.sharepoint.com/sites/BOVendorManagement BO Vendor Management
2 https://poluk.sharepoint.com/sites/K2Demo K2 Demo
33
POL-BSFF-0090111_0032
POL00252048
POL00252048
1777 https://poluk.sharepoint.com/sites/Pathfinder Pathfinder
2000 https://poluk.sharepoint.com/sites/POLIntegrationCentreofExcellenceTeam POL Integration Centre of Excellence Team
8 https://poluk.sharepoint.com/sites/ProcurementSystemsImprovement Procurement Systems Improvement
1 https://poluk.sharepoint.com/sites/Objectives Objectives
1 https://poluk.sharepoint.com/sites/Area7Team14 Area 7 Team
1 https://poluk.sharepoint.com/sites/Area1Team36 Area 1 Team
509 https://poluk.sharepoint.com/sites/Workflow Workflow
1 https://poluk.sharepoint.com/sites/AreaSTeam14 Area 5 Team
17 https://poluk.sharepoint.com/sites/Fit&Proper Fit & Proper
95837 https://poluk.sharepoint.com/sites/A674 Property Projects Team
1 https://poluk.sharepoint.com/sites/Area7Team69 Area 7 Team
1 https://poluk.sharepoint.com/sites/Area8Team47 Area 8 Team
1 https://poluk.sharepoint.com/sites/TheW ildWest The Wild West!
160 https://poluk.sharepoint.com/sites/A1288 Newcastle CVIT Team Site
5 https://poluk.sharepoint.com/sites/IT Portfolio Office IT Portfolio Office
14379 https://poluk.sharepoint.com/sites/A1069 Information Services Chesterfield
1 https://poluk.sharepoint.com/sites/AreagTeam79 Area 9 Team
367 https://poluk.sharepoint.com/sites/A1139. MS Payout Implimentation
2 https://poluk.sharepoint.com/sites/FAandGovernance Financial Accounting and Governance
34
POL-BSFF-0090111_0033
POL00252048
POL00252048
5 https://poluk.sharepoint.com/sites/K2 K2 Home
695 https://poluk.sharepoint.com/sites/A999GPTest Gareth Payne Alerting Test
1 https://poluk.sharepoint.com/sites/BOResourcing BO Resourcing
1 https://poluk.sharepoint.com/sites/Area10Team69 Area 10 Team
2 https://poluk.sharepoint.com/sites/BOFLMGTPROD BOFLMGTPROD
665 https://poluk.sharepoint.com/sites/POA005 Survey Central
11 https://poluk.sharepoint.com/sites/FraudAnalsisTeam Fraud Analsis Team
1 https://poluk.sharepoint.com/sites/RVP RVP
1 https://poluk.sharepoint.com/sites/OnePostOffice13 One Post Office
1 https://poluk.sharepoint.com/sites/BusinessandITCommsDiscussion Business and IT Comms Discussion
1 https://poluk.sharepoint.com/sites/TelcoHackathon Telco Hackathon
1 https://poluk.sharepoint.com/sites/DMBDeliveryLeadTeam DMB Delivery Lead Team
247 https://poluk.sharepoint.com/sites/DBSIdentityChecksS4-023-00 DBS Identity Checks (S4-023-00)
108 https://poluk.sharepoint.com/sites/POMSHR POMS HR
1 https://poluk.sharepoint.com/sites/FraudAnalyticsteam Fraud Analytics team
1 https://poluk.sharepoint.com/sites/TechnicalBOTStream Technical BOT Stream
1 https://poluk.sharepoint.com/sites/DynamicsCRM Dynamics CRM (TDC)
15517 https://poluk.sharepoint.com/sites/POLNMSP1 POLNMSP1
96187 https://poluk.sharepoint.com/sites/ResolveRepository Resolve Repository
35
POL-BSFF-0090111_0034
POL00252048
POL00252048
1 https://poluk.sharepoint.com/sites/SeanL-FS&TLRG&POMS Sean L - FS&T, LRG & POMS
1 https://poluk.sharepoint.com/sites/Area10Team42 Area 10 Team
1 https://poluk.sharepoint.com/sites/StaffHub994b9 K2 Dev Team
51 https://poluk.sharepoint.com/sites/ARTProject ART Project
1 https://poluk.sharepoint.com/sites/TEST19. TEST
1 https://poluk.sharepoint.com/sites/TeamTony86 Team Tony
5240 https://poluk.sharepoint.com/sites/Property Finance Team Property Finance Team
9136 https://poluk.sharepoint.com/sites/SCPlanningPerformance&Change Planning Performance & Change
1 https://poluk.sharepoint.com/sites/Star Star
6 https://poluk.sharepoint.com/sites/PCE PCE
382 https://poluk.sharepoint.com/sites/Project Panther Project Panther
2 https://poluk.sharepoint.com/sites/Pensions Pensions
1 https://poluk.sharepoint.com/portals/FSAM-North FSAM North
8 https://poluk.sharepoint.com/sites/IPA IPA
1 https://poluk.sharepoint.com/sites/Area3Team89 Area 3 Team
1 https://poluk.sharepoint.com/sites/KennyLamontNorth Kenny Lamont North
1 https://poluk.sharepoint.com/sites/ClosedProjects Closed Projects.
1 https://poluk.sharepoint.com/sites/FRESEngagement FRES Engagement
1 https://poluk.sharepoint.com/sites/OnePostOffice66 One Post Office
36
POL-BSFF-0090111_0035
POL00252048
POL00252048
1 https://poluk.sharepoint.com/sites/POLGE POL GE
1 https://poluk.sharepoint.com/sites/workflow.admin Workflow
2 https://poluk.sharepoint.com/sites/OfficeSpace Office Space
1 https://poluk.sharepoint.com/portals/hub PointPublishing Hub Site
1 https://poluk.sharepoint.com/sites/CustomerExperience Customer Experience
2 https://poluk.sharepoint.com/sites/Royston House Royston House
8 https://poluk.sharepoint.com/sites/SecurityPO. Security@PO
3 https://poluk.sharepoint.com/sites/RemoteDesktopSupport Remote Desktop Support
2 https://poluk.sharepoint.com/sites/NetworkPartnershipsTeam The Hive
1 https://poluk.sharepoint.com/sites/OnePostOffice41 One Post Office
1 https://poluk.sharepoint.com/sites/TransactionSimplificationSDT 1 Transaction Simplification SDT1
1 https://poluk.sharepoint.com/sites/BOTStakeholderMgnt BOT Stakeholder Mgnt
1 https://poluk.sharepoint.com/sites/BSTDataTeam BST Data Team
70949 https://poluk.sharepoint.com/sites/A1012 Customer Driven Enquiries
294 https://poluk.sharepoint.com/sites/A1010. Strategy and Change Team
1 https://poluk.sharepoint.com/sites/NDProgramme77 ND Programme
206 https://poluk.sharepoint.com/sites/C4Grads C4 Grads
5 https://poluk.sharepoint.com/sites/POLEnterpriseArchitects POL Enterprise Architects
2 https://poluk.sharepoint.com/sites/MainsDevelopmentAdvisors Mains Development Advisors
37
POL-BSFF-0090111_0036
POL00252048
POL00252048
1067 https://poluk.sharepoint.com/sites/A489 POL NT Database Project
1 https://poluk.sharepoint.com/sites/AreaSTeam93. Area 5 Team
1 https://poluk.sharepoint.com/sites/staffordcasestudy stafford case study
23 https://poluk.sharepoint.com/sites/RetailleadTeam Retail Lead Team
47779 https://poluk.sharepoint.com/sites/A101 1 Client Settlement
1 https://poluk.sharepoint.com/sites/OurUnitLaunch Our Unit Launch
1 https://poluk.sharepoint.com/sites/Area9Team44 Area 9 Team
1 https://poluk.sharepoint.com/sites/Area9Team47 Area 9 Team
1 https://poluk.sharepoint.com/sites/POLGeneral POL General
1 https://poluk.sharepoint.com/sites/Area6Team55 Area 6 Team
1 https://poluk.sharepoint.com/sites/wc04September2017 we 04 September 2017
18 https://poluk.sharepoint.com/sites/TeamTony97 Team Tony
56 https://poluk.sharepoint.com/ intranet
49362 https://poluk.sharepoint.com/sites/A1014 Debt Recovery
1 https://poluk.sharepoint.com/sites/Area10Team21 Area 10 Team
1 https://poluk.sharepoint.com/sites/ITApprentices IT Apprentices
379038 https://poluk.sharepoint.com/sites/postoffice the hub
8727 https://poluk.sharepoint.com/sites/A092 National Storage & Distribution Centre Swindon
79 https://poluk-my.sharepoint.com/
38
POL-BSFF-0090111_0037
POL00252048
POL00252048
1 https://poluk.sharepoint.com/sites/LRGPurchaseOrders. LRG Purchase Orders
1 https://poluk.sharepoint.com/sites/Area6Team19 Area 6 Team
14 https://poluk.sharepoint.com/sites/ChangeManagementSystems. Change Management Systems
938 https://poluk.sharepoint.com/sites/POLDev POL Development Site
573 https://poluk.sharepoint.com/sites/Identityservicesstrategy504 Identity services strategy
3 https://poluk.sharepoint.com/sites/ITSecurity&OperationsLeadershipteam IT Security & Operations Leadership team
1 https://poluk.sharepoint.com/sites/Area1Team89 Area 1 Team
1 https://poluk.sharepoint.com/sites/Area2Team94 Area 2 Team
3614 https://poluk.sharepoint.com/sites/Extranet Post Office Extranet
1 https://poluk.sharepoint.com/sites/Area1Team69 Area 1 Team
10 https://poluk.sharepoint.com/sites/RiskLeadershipForum Risk Leadership Forum
14 https://poluk.sharepoint.com/portals/community Community
9 https://poluk.sharepoint.com/sites/MainsSalesManagers Mains Sales Managers
115 https://poluk.sharepoint.com/sites/CRMTablets CRM+ Tablets
1 https://poluk.sharepoint.com/sites/Area5Team23 Area 5 Team
1180 https://poluk.sharepoint.com/sites/BIM. BIM
1360 https://poluk.sharepoint.com/sites/BackOffice Transformation BOT ARCHIVED
27 https://poluk.sharepoint.com/search
1 https://poluk.sharepoint.com/portals/personal/darrenjones1 darren jones1
39
POL-BSFF-0090111_0038
POL00252048
POL00252048
32 https://poluk.sharepoint.com/sites/Swansea CViT Shared Swansea CViT Shared
1 https://poluk.sharepoint.com/sites/test107 test
1 https://poluk.sharepoint.com/sites/Team5 Team 5
74 https://poluk.sharepoint.com/sites/ClOPeople CIO People
51 https://poluk.sharepoint.com/sites/Managementinformation BOT Management Info
1 https://poluk.sharepoint.com/sites/Area9Team57 Area 9 Team
1 https://poluk.sharepoint.com/sites/Area2Team83 Area 2 Team
1 https://poluk.sharepoint.com/sites/thehub the hub
110 https://poluk.sharepoint.com/sites/A796 North - Sales Capability Managers.
2 https://poluk.sharepoint.com/sites/K2UAT K2UAT
7573 https://poluk.sharepoint.com/sites/A1028 POL Core Finance
1974 https://poluk.sharepoint.com/sites/A1207 London East Cash Centre
1 https://poluk.sharepoint.com/sites/OnePostOffice7 1 One Post Office
42 https://poluk.sharepoint.com/sites/Prism Prism
2 https://poluk.sharepoint.com/sites/one one
58 https://poluk.sharepoint.com/sites/Products Products
2 https://poluk.sharepoint.com/sites/BDC. BDC
27029 https://poluk.sharepoint.com/sites/A1013. Open Item Enquiries
10 https://poluk.sharepoint.com/sites/JoinersMoversLeavers Joiners Movers & Leavers
40
POL-BSFF-0090111_0039
POL00252048
POL00252048
58 https://poluk.sharepoint.com/sites/A1068 Business Information Management
1 https://poluk.sharepoint.com/sites/Area4Team2 Area 4 Team
1 https://poluk.sharepoint.com/portals/personal/syedmraza syed.m.raza
1 https://poluk.sharepoint.com/sites/BIM-MasterDataTeam BIM - Master Data Team
28 https://poluk.sharepoint.com/sites/Identity Identity
10 https://poluk.sharepoint.com/sites/Postmaster Remuneration and Policy Team Postmaster Remuneration and Policy Team
146 https://poluk.sharepoint.com/sites/P6 P6
1 https://poluk.sharepoint.com/sites/Area6Team15 Area 6 Team
1 https://poluk.sharepoint.com/sites/ATM ATM
1 https://poluk.sharepoint.com/sites/W orkduties Work duties
1 https://poluk.sharepoint.com/sites/CommunicationsDelivery Communications Delivery
1 https://poluk.sharepoint.com/sites/DigitalCheckandSend-POL-Accenture-Gemalto Digital Check and Send - POL/Accenture/Gemalto
1 https://poluk.sharepoint.com/portals/personal/maximlaithwaite maxim. laithwaite
3 https://poluk.sharepoint.com/sites/eDiscovery Millnet EDiscovery
18 https://poluk.sharepoint.com/sites/RoysAreadailyReport Roy's Area daily Report
1 https://poluk.sharepoint.com/sites/Vetting-StrategicSolution Vetting- Strategic Solution
1 https://poluk.sharepoint.com/sites/Panther Panther
1 https://poluk.sharepoint.com/sites/StaffDutyCover Staff Duty Cover
5 https://poluk.sharepoint.com/sites/DesignAuthority Design Authority
41
POL-BSFF-0090111_0040
POL00252048
POL00252048
1 https://poluk.sharepoint.com/sites/Agencybranch Agency branch
86 https://poluk.sharepoint.com/sites/Securitytransformation Security transformation
10 https://poluk.sharepoint.com/sites/ATMW orkingGroup ATM Working Group
1 https://poluk.sharepoint.com/sites/NDProgramme63 ND Programme
1 https://poluk.sharepoint.com/portals/personal/michaelarlington michael.arlington
1 https://poluk.sharepoint.com/sites/ND ND
232 https://poluk.sharepoint.com/sites/A979. OD Team Site
17 https://poluk.sharepoint.com/sites/ProductManagersDevelopment Product Managers Development
2 https://poluk.sharepoint.com/sites/BOFLMGTDEV BOFLMGTDEV
1 https://poluk.sharepoint.com/sites/Area4Team15 Area 4 Team
4849 https://poluk.sharepoint.com/sites/NDStrategy ND Strategy
11833 https://poluk.sharepoint.com/sites/A654 Network Design & Analysis Team
5226 https://poluk.sharepoint.com/sites/BTTP Training Design Team Learning Design Team - Projects
1 https://poluk.sharepoint.com/sites/test test
323 https://poluk.sharepoint.com/sites/Measurement & Reporting Key Database Measurement & Reporting Key Database
1 https://poluk.sharepoint.com/sites/TeamRhi Team Rhi
1005 https://poluk.sharepoint.com/sites/Drop & Go Project Drop & Go
1 https://poluk.sharepoint.com/sites/TEST66. TEST
6 https://poluk.sharepoint.com/sites/SSKProcurement SSK Procurement
42
POL-BSFF-0090111_0041
POL00252048
POL00252048
1 https://poluk.sharepoint.com/portals/personal/alinalingard alina.lingard
22865 https://poluk.sharepoint.com/sites/A997 Supply Chain Operations Team Drives
1469 https://poluk.sharepoint.com/sites/A044 Network Gateway
1 https://poluk.sharepoint.com/sites/Area4 Team98 Area 4 Team
1 https://poluk.sharepoint.com/sites/NetworkSolutions Network Solutions
1 https://poluk.sharepoint.com/sites/Chesterfield Chesterfield
1 https://poluk.sharepoint.com/sites/rotherham rotherham
106 https://poluk.sharepoint.com/sites/LondonDailyReports London Daily Reports
1 https://poluk.sharepoint.com/sites/Area2Team76 Area 2 Team
6036 https://poluk.sharepoint.com/sites/A107 1 Physical Security Sharepoint Site
1 https://poluk.sharepoint.com/sites/Area6 Team78 Area 6 Team
1 https://poluk.sharepoint.com/sites/TEST752 TEST
1 https://poluk.sharepoint.com/sites/skms_dev SKMS Development
43
POL-BSFF-0090111_0042
APPENDIX E
Third Party Electronic Documents
POL00252048
POL00252048
A range of third parties provide support and services to Post Office and may hold documents which are relevant to this litigation. Whilst many of these
documents are not within Post Office's control and therefore do not fall to be disclosed by it, in the interests of assisting the Claimant and the Court, Post
Office sets out below a high level overview of these documents.
It should be noted that to assess whether documents held by third parties fall within Post Office's contro! will not be a straightforward task, It will require a
close reading of the relevant contractual documents between Post Office and the relevant Third Party and precise identification of the documents or
information in question. Post Office considers that this assessment is best done retrospectively, after a document or class of documents has been identified
as being needed for this litigation. It may also be the case that some third parties (eg. Fujitsu) would be willing to voluntarily disclose some documents.
regardless of whose control they are under. It is therefore most cost effective and constructive to deal with issues of control on an iterative basis.
Some of these products and services
have their own bespoke databases of
information within Post Office.
Furthermore, most of these products and
services are provided by third parties and
re-sold by Post Office. The third party
product / service suppliers (known as
"Clients" within Post Office) may hold
information about related customer
transactions in their own IT systems.
(eg. email, phone, etc,) and
file storage (eg. Sharepoint,
shared drives, etc.).
It may also include various
customised and proprietary
databases.
Third Party I Brief description of documents and I Nature of information held I Are these documents within the Proposals for provision of
information scope of disclosure? relevant documents to or
access by other parties to
this litigation
Products Post Office offers in excess of 100 I Various but likely to include I No N/A
and products and services to customers (eg. I all commonly used file types
Services Lottery, DVLA, bill payments, etc,). (eg. Word, pdf, etc.), I The Generic pleadings do not refer to
communication methods I any specific product or service and
Post Office therefore considers that
these documents are currently outside
the scope of disclosure.
If, as this litigation progresses, issues
are raised in relation to specific
products or services, a further EDQ
may be filed providing more detail on
these databases and the documents
held by relevant third parties.
44
POL-BSFF-0090111_0043
POL00252048
POL00252048
IT Support
Partners
Post Office has had numerous IT support
partners between 1999 and present.
This includes = Accenture, ATOS
ComputaCenter and Fujitsu. Each may
hold information relating to Horizon and
other relevant IT systems.
Due to the central role of Horizon in this
litigation, more detailed information on
the documents held by Fujitsu is set out
below.
Various
Save for Fujitsu, no.
It is expected that the majority of the
information held by these support
partners will be mirrored inside Post
Office on emails held by Key
Custodians or in Post Office's
databases.
If, as this litigation progresses, issues
are raised in relation to specific areas
supported by a third party IT support
partner, a further EDQ may be filed
providing more detail on the
documents held by that third party.
In relation to documents held by
Fujitsu, disclosure of these documents
can be discussed following exchange
of EDQs.
N/A
45
POL-BSFF-0090111_0044
FUJITSU DOCUMENTS
Fujitsu provides a range of IT services to Post Office in relation to the Horizon system throughout the relevant period.
POL00252048
POL00252048
As a result, there are a significant
number of documents within Fujitsu's possession which may be relevant. Below is a high level overview of:
. the locations of documents held by Fujitsu that are potentially relevant to the Claim;
. the types of document held by Fujitsu that are potentially relevant to the Claim; and
. comments regarding the ease and proportionality of disclosure of the documents.
This information has been provided by Fujitsu to Post Office.
Known Error Log (KEL)
The KEL is a proprietary database with approximately
4,000 entries containing information which is used by
Fujitsu to explain how to deal with or work around minor
issues that can sometimes arise in Horizon and Horizon
Online for which (often because of their triviality) system-
wide fixes have not been developed and implemented.
The KEL only contains the current database entries and is
constantly updated and so the current version will not necessarily
reflect the version that was in place at the relevant time. The
previous entries / versions of the current entries are no longer
available.
The KEL cannot be easily downloaded as it is stored on a
database. Even then, unless one has the necessary database
software, reading the data in the KEL is difficult. The alternative is
to manually copy or print each entry, but this would produce poorly
formatted material and would take significant effort.
In light of this, the Claimant's IT expert has inspected the KEL at
Fujitsu's offices.
Dimensions
Dimensions is a configuration management system in
which Fujitsu keeps a library of the key technical
documents relating to Horizon and Horizon Online. The
documents range from high level designs to detailed
designs of the system and its code, along with
documents that describe hardware that is used in the
system. A full index of these documents has been
provided to the Claimant's solicitors.
The documents are formatted in various formats including Word,
PDF, Excel, PowerPoint, Visio and in a zipped format. Most
documents can be extracted from Dimensions.
Asmall number of older (pre-2001) documents that are believed to
be non-Fujitsu documents were received in hardcopy and not
scanned in. It may be possible to locate the hardcopies in archives
or it may be that another party is better placed to provide these
documents if relevant.
46
POL-BSFF-0090111_0045
POL00252048
POL00252048
Peak System
If Fujitsu identifies an issue in Horizon or Horizon Online
that requires a programmatic fix then it is logged in its
database, the Peak System, and labelled as a 'Peak'.
If Fujitsu identifies an issue in Horizon that requires a
programmatic fix then it is logged in its database, the Peak
System, and labelled as a ‘Peak’.
TFS and Powerhelp
Post Office and its agents have access to a help desk
called Horizon Service Desk (HSD) to manage technical
issues with Horizon — HSD was provided by Fujitsu prior to)
June 2014 (and has been provided by ATOS since that
date).
Between 2001 and September 2009, Fujitsu used
Powerhelp to log calls. From September 2009 onwards,
Fujitsu used Triole for Service (TFS), a proprietary
database, to log calls made to HSD.
TFS call logs date back to September 2009. These call logs could
be extracted from TFS into an Excel document. Powerhelp may
contain call logs for the period between 2001 and September 2009,
however, Fujitsu has advised that the Powerhelp servers are still
stored but they do not currently have the means to access them;
they would have to recreate a ring fenced network running WindowsI
2003 (the redundant software on which Powerhelp was run).
SharePoint and shared drives
Projectweb
SharePoint has been used by Fujitsu since c.2008 to store
and share documents it produces relating to Post Office .
Shared drives are also used for a similar purpose.
Prior to 2008, Fujitsu used a self-built system, Project
Web, for this purpose. This system is still available in a
read-only format, although access to the system is by
temporary arrangement because it is a legacy system.
As explained in relation to the extraction of documents from Post
Office's SharePoint, similar issues may be encountered when
extracting documents from Fujitsu's SharePoint.
Documents stored in SharePoint, shared drives and ProjectWeb areI
generally regarded as uncontrolled, working documentation that is
not held in a completely formalised structure, in contrast to the
Dimensions depository.
Emails
The vast majority of Fujitsu's internal communications take
place via email.
Fujitsu does not operate a formal email archiving policy or system.
Therefore, to the extent that any emails are not stored in other
accessible locations, availability will be limited to those held in
individual users' email accounts. As users have a storage limit on
their accounts, emails are routinely deleted from the user's own
email account but may be subsequently stored in locally held .pst
files.
On average, between 250 to 400 people at Fujitsu work on Post
Office's account at one time. Consequently, there have been
thousands of people at Fujitsu who have worked on Horizon over
the 17 years since the system was developed.
Local computers
It is possible that Fujitsu staff will have also stored relevant
documents locally on their individual Fujitsu PCs or local
storage devices. It is believed that most users will also
47
POL-BSFF-0090111_0046
POL00252048
POL00252048
have saved any such documents into another networked
repository (even if only via email).
48
POL-BSFF-0090111_0047
APPENDIX F
Hardcopy documents
POL00252048
POL00252048
Hard copy documents
Several teams are still
paper-based or regularly use
paper records and for the
sake of completeness we
have listed below.
Former Agent Debt
The Former Agent Debt
team in FSC is an example
of a team that is primarily
paper-based. Documents
for current postmasters are
stored at Post Office's
Chesterfield office and
documents relating to former
postmasters are archived by
Box-It (formerly Iron
Mountain) at Post Office's
Chesterfield office. These
files are organised by an
account reference that ties
to POL SAP.
Yes
OCR documents.
Current Agent debt
Limited hard copy
documents stored at Post
Office's Chesterfield office.
Majority of documents would
be a duplication of
documents stored in
SharePoint or Core Finance.
Yes
OCR documents.
Contract Advisors
The Contract Advisors team
keep electronic records in
Yes
OCR documents.
49
POL-BSFF-0090111_0048
POL00252048
POL00252048
Lotus Notes, SharePoint and
One Drive but also hard
copy files. Current
postmaster files are kept at
Post Office's Chesterfield
offices. These files are
organised by branch.
Former postmaster files are
stored off-site. Ifa
Postmaster's file has been
closed and archived for a
period of more than 6 years,
the file may be securely
destroyed. This process is
now on hold.
Security The Security team maintains I Yes OCR documents.
electronic files but also hard
copy files, referred to
internally as "Green
Jackets". These files are
primarily stored in
Chesterfield but would also
be circulated amongst Post
Office's Legal or Fraud
teams, or to external legal
advisers so may be stored in
other locations.
Branch records Postmasters are required as I Yes OCR documents.
part of branch process to run
certain reports every month
and retain a paper copy.
Once an agent's contract
terminates, Post Office will
typically remove this
documentation from the
branch and store it off-site
50
POL-BSFF-0090111_0049
POL00252048
POL00252048
with Box-lIt or Iron Mountain.
Destruction of files within
these facility has been
placed on hold. Claimants
who are current postmasters
will hold these records within
their branches.
Some of the reports are not
printed on A4 sheets but on
till rolls which are several
feet. long. Each branch will
have generated reports each
month, potentially
generating dozens of boxes
of paper over the course of
several years. Following
exchange of EDQs the
parties will discuss the
reasonableness and
proportionality of disclosing
these documents.
Mediation Scheme Hard copy documents are Yes OCR documents.
stored in the cash centre in
Swansea and Post Office's
Finsbury Dials office.
51
POL-BSFF-0090111_0050
POL00252048
POL00252048
Claim No: HQ16X01238 and HQ17X02637
IN THE HIGH COURT OF JUSTICE
QUEEN'S BENCH DIVISION
THE POST OFFICE GROUP LITIGATION
BETWEEN:
ALAN BATES & OTHERS
Claimant
AND
POST OFFICE LIMITED
Defendant
APPENDIX G
52
POL-BSFF-0090111_0051
womblebonddickinson.com
22 November 2017
Third letter
Freeths LLP
Floor 3
100 Wellington Street
Leeds
Womble Bond Dickinson (UK) LLP
Oceana House
39-49 Commercial Road
Southampton
$015 1GA
Telt
F
andrew.parson:
Directs
LS1 4LT
Our ref:
7 AP6IAPG/364065.1369
By post and email Your ref:
POL00252048
POL00252048
JXHI1684/2113618/1
Email: james.hartley
Dear Sirs
The Post Office Group Action
Disclosure of Transaction and Event Data
We refer to paragraph 4(a)(iv) of the CMC Order which concerns the disclosure of the transaction and
event data (the Data). We write to provide Post Office's proposals on the format in which this data is
disclosed.
We have been informed by Fujitsu that there are a vast number of fields available in the database which
hosts the Data and that over time these fields have changed. When Fujitsu extract the Data it is usually
filtered so that it only includes those fields which relate to transactions and events which would affect a
branch's accounts. At Schedule 1 is an example of the Data and the fields which are extracted through
running this report, along with an explanation of the fields.
To disclose the unfiltered Data would require it to be extracted in a .txt format (rather than in .xIsx which
can be read by Excel) and converted into a readable format. Further, the unfiltered Data would be
between 10GB and 100GB of data per month depending on the size of the branch and the activity in that
branch during the month. This compares to the 1MB of data per month in the filtered format. The
hosting of 400 months of unfiltered Data by our third party e-discovery partner would cost between
£100,000 and £1million per a month. Post Office therefore proposes that it would be reasonable and
proportionate to only provide the Data in the filtered format as set out in Schedule 1. As you will see,
this filtered data is still extensive and will provide the information necessary for the purposes of this
litigation.
Further, the extraction of the Data is a time-consuming process and to ensure that the Data is extracted
and disclosed by 19 January 2018 it would be appreciated if when informing us of your Potential Lead
Claimants you could also confirm the months of Data which you would like disclosed.
If you have any queries on the filtering of the Data or would like to discuss this proposal please let us
know by 4pm on 25 November 2017.
Womble Bond Dickinson (UK) LLP is a limited liability partnership registered in England and Wales under number 0C317661. VAT registration
number is GB123393627. Registered office: 4 More London Riverside, London, SE1 2AU, where a list of members’ names is open to inspection. We
use the term partner to refer to a member of the LLP, or an employee or consultant who is of equivalent standing. Womble Bond Dickinson (UK) LLP
is authorised and regulated by the Solicitors Regulation Authority
Womble Bond Dickinson (UK) LLP is a member of Womble Bond Dickinson (International) Limited, which consists of independent and autonomous
law firms providing services in the US, the UK, and elsewhere around the world. Each Womble Bond Dickinson entity is a separate legal entity and is
not responsible for the acts or omissions of, nor can bind or obligate, another Womble Bond Dickinson entity. Womble Bond Dickinson (International)
Limited does not practice law. Please see www.womblebonddickinson.comv/legal notices for further details.
4A_37502236_1
POL-BSFF-0090111_0052
POL00252048
POL00252048
Yours faithfully
Udemv= Benct Diciunsen
Womble Bond Dickinson (UK) LLP
54
4A_37502236_1 2
POL-BSFF-0090111_0053
TRANSACTION DATA — EXAMPLE
SCHEDULE 1
POL00252048
POL00252048
ymaoo1 I AA 01-Jun-2010 I 08:26:19 44- 44-179714-1- I SC 1 4 -4.07
179714-1- I 2151364-3
2151364-1
I ee — I
yMag01 I AA Ot-Jun-2010 I 08:27:51 44 44-179714-1- I SC 4925 A I -100
179714-1- I 2151375-2
2151375-1 I I
JMAoO1 I AA 01-Jun-2010 I 08:29:16 44- 44-179714-1- I SC 134 1 10 I
179714-1- I 2151382-1
2151375-1 I
! I I
_I
633641VjCTEJ2396 I AQBIAH8GCokdiIRkIAlrsyXsQNs=
BT Payment Card I 894400001 1849265424
User
ID of the branch user who undertook the transaction.
SU
The stock unit in which the transaction was undertaken.
4A_37502236_1
55
POL-BSFF-0090111_0054
Date & Time Date and time of the transaction.
Sessionid Each session is given a sequential number and all transactions undertaken in the same session are given
the same ID so as to group transactions into sessions.
Txnid This shows the unique identifier for individual transactions.
Mode Defines tre state/mode in which the counter PC was operating at the time of the transaction.
Reversal Indicates if the transaction was reversed
ProductNo The product number indicates which product was being transacted.
Qty The number (quantity) of a specific product in the transaction.
SaleValue The value of the transaction undertaken.
EntryMethod Specifies how a transaction was entered by a clerk at a counter.
PAN The Primary Account Number (which includes the Issuer Identification Number). This is a series of up to 19
digits on a card used to identify a particular card, customer account or relationship.
I EPAN Encrypted Primary Account Number. I
CN Additional Information (i.e. use of the pay station, NS&I investment accounts, special delivery).
Barcode References which relate to additional information (i.e. tracking barcode for Special Delivery mail items).
Sortcode Customer's bank/buildirig society sort code for the account used for the transaction.
Account Number Customer’s bank/buildirig society account number used for the transaction.
4A_37502236_1
POL00252048
POL00252048
56
POL-BSFF-0090111_0055
POL00252048
POL00252048
EVENT DATA
166539 I 1 GJEO01 02/01/2013 I 16:42:02 I AA 21 Declare CURRENCY Total 1000.00 For SU AA Till 1
Groupld FAD Code of the branch in which the event occurred. I
Id This is the unique identifier for the node / counter in the branch on which the transaction was undertaken. I
User ID of the branch user who undertook the event. I
Date & Time Date and time of the event. I
Stock Unit Stock unit in which the event took place.
I
reportingEventID I The identification number of the report that has been produced. I
eventDetailMsg Explanation of the event. I
— i
57
4A 375022361 3
POL-BSFF-0090111_0056
POL00252048
POL00252048
Claim No: HQ16X01238 and HQ17X02637
IN THE HIGH COURT OF JUSTICE
QUEEN'S BENCH DIVISION
THE POST OFFICE GROUP LITIGATION
BETWEEN:
ALAN BATES & OTHERS
Claimant
AND
POST OFFICE LIMITED
Defendant
APPENDIX H
58
POL-BSFF-0090111_0057
POL00252048
POL00252048
womblebonddickinson.com
WOMBLE
BOND
DICKINSON
14 November 2017 Womble Bond Dickinson (UK) LLP
Oceana House
39-49 Commercial Road
For the Attention of Mr J Hartley Porperel
Freeths LLP
100 Wellington Street
Leeds
West Yorkshire
LS1 4LT
( Our ref:
By email only AP6/AP6/364065. 1369.
Your ref
JXHI1684/2117463/1/MA
Email: james.hartley GRO “I
Dear Sirs
The Post Office Group Action
Proposals for the Exchange of Electronic Data
We write in advance of the disclosure under paragraphs 4 and 13 of the CMC Order to provide Post
Office's proposals on how documents should be exchanged. Our objective is to try to streamline the
practical steps involved in disclosing documents for the benefit of both parties. These proposals are not
intended to be exhaustive; there may be certain categories of documents that do not fit with the structure
we have proposed below.
We welcome your comments on these proposals.
1. Disclosure List
It is proposed that each party maintains a Disclosure List of the documents which they have disclosed in
an Excel spreadsheet. The Disclosure List would contain all of the documents which have been
disclosed and we suggest that they should be organised in the following manner:
cl The documents are sorted into chronological order, with any attachments listed directly
below their parent. The documents for each Claimant are grouped together and any
"generic" documents (disclosed by Post Office) should be grouped separately.
. The list should contain, unless impracticable, the fields set out below.
Disclosure Date Since disclosure will take place in a staged manner, DD/MM/YYYY
the list would include the date on which disclosure of
that document was provided.
Claimant No. Claimant's number as per the Claim Form. Where 19
Post Office discloses documents which relate to more
than one Claimant then we propose that these are
marked "Generic".
Womble Bond Dickinson (UK) LLP is a limited liability partnership registered in England and Wales under number 0C317661. VAT registration
number is GB123393627. Registered office: 4 More London Riverside, London, SE1 2AU, where a list of members’ names is open to inspection. We
use the term partner to refer to a member of the LLP, or an employee or consultant who is of equivalent standing. Womble Bond Dickinson (UK) LLP
is authorised and regulated by the Solicitors Regulation Authority.
Womble Bond Dickinson (UK) LLP is a member of Womble Bond Dickinson (International) Limited, which consists of independent and autonomous
law firms providing services in the US, the UK, and elsewhere around the world. Each Womble Bond Dickinson entity is a separate legal entity and is,
not responsible for the acts or omissions of, nor can bind or obligate, another Womble Bond Dickinson entity. Womble Bond Dickinson (International)
Limited does not practice law. Please see www.womblebonddickinson.comilegal notices for further details.
4A_37409605_2
59
POL-BSFF-0090111_0058
POL00252048
POL00252048
Disclosure ID See below for more details.
Disclosure This ensures that families of documents can be
Attached To identified. The Disclosure Attached To number for a
family document is inherited from the Disclosure
Number of the parent document.
Sort Date The sort date is used to ensure that families of DD/MM/YY HH:MM
documents are kept together on the list. For emails
with attachments, the date of the parent would be
pushed down to the attachment to ensure that these
remain together on the list.
For parent documents this is the primary date of the
document. For child documents, this the date of the
parent document.
Document Date
I
The primary date of a document is typically the best
I date that we are able to ascribe to the document when
it is processed. Typically, this would be the date on
which it was last modified and, in the case of an email,
this would simply be the date the email was sent or
received.
In circumstances where this meta data is not available
(either due to the extraction process or being a
scanned hardcopy document) then it should be brought
to the other parties attention that this is an estimated
date.
DD/MM/YY HH:MM
Document This information is intended to contain the meta data
Subject / Title value extracted from the document subject or title.
File Name This information is intended to contain the meta date
value extracted from the file name.
Document Type This field should be based on the file signature. Microsoft Word
Document
Author The name of the person who sent or created the
document.
Recipient/s The name of the person(s) who received the
document.
cc The name of the person(s) who were copied in on the
document.
MD5 Hash Value I The 32 digit hash value generated for the purpose of
de-duplication.
Redacted Confirmation of whether a document has been Yes / No
redacted.
4A_37409605_2
* 60
POL-BSFF-0090111_0059
POL00252048
POL00252048
2. Document Reference Numbers
21 Post Office proposes that every document is assigned a unique Disclosure ID. This should be a
sequential number prefixed by the disclosing party's ID. For example, we intend to use POL-
00000001
2.2 For the Claimants’ disclosure, it is important that the exact disclosing Claimant is known. It would
not be workable for the Claimants’ disclosure to be collated together and given on behalf of the
group. Each Claimant should give their own disclosure, even if this means disclosing duplicate
copies of documents across multiple Claimants. This is important because:
2.2.1 Our client will need to use the documents in cross-examination and can only do so
effectively if it knows which documents relate to or were sourced from which
Claimants.
2.2.2 Our client has alleged that a number of the Claimants have acted dishonestly and
documents in their possession (or the absence of documents in their possession) may
be probative on this question.
2.2.3 Our client may wish to draw inferences where a particular Claimant has not preserved
relevant documents.
23 We therefore suggest that the Claimants use the following convention: C-001-0000001. "C" for
Claimant. The second number is a particular Claimant's claim number on a claim form. The final
long number is a sequential unique identification number.
3. Format of Exchange
3.4 Electronic documents
It is proposed that these documents be exchanged in their native format, with the exception of
those which have been redacted, along with the metadata set out above.
3.2 Hard copy documents
It is proposed that hard copy documents be scanned as a PDF image and be scanned as black
and white, or if colour is required to understand the documents (plans / graphs / photos) then
should be scanned in colour. Further, OCR should be used to make the PDFs text searchable
and they should be manually coded with the information set out above.
3.3 Redacted documents
It is proposed that redactions are marked with a black box and documents which have been
redacted will be exchanged in PDF format.
4. Method of exchange
Post Office proposes that the data should be exchanged by way of a Data Exchange File in a .dat
file format. The documents should be provided to the other party for inspection on an appropriate
disk of medium which is encrypted.
We would welcome your thoughts on the above proposals. If it would be convenient to arrange a call to
discuss these proposals please could you confirm a convenient time. Moreover, if you have already
engaged an e-disclosure support partner, it may be worth them talking directly to Advanced Discovery,
our e-disclosure support partner.
4A_37409605_2 2 64
POL-BSFF-0090111_0060
POL00252048
POL00252048
Yours faithfully
yoonnle Bord Doeurion Ge) Up
Womble Bond Dickinson (UK) LLP
4A_37409605_2 “ 62
POL-BSFF-0090111_0061