THE POST OFFICE GROUP LITIGATION
IN THE HIGH COURT OF JUSTICE.
QUEEN'S BENCH DIVISION
ROYAL COURTS OF JUSTICE
BETWEEN:
ALAN BATES & OTHERS
AND
POST OFFICE LIMITED
Claim No:
HQ17X04248
HQ16X01238, HQ17X02637 AND
Claimant
Defendant
POST OFFICE'S RESPONSE TO JASON COYNE'S "REQUESTS FOR INFORMATION" DOCUMENT SENT ON 12 JULY 2018 and DATED 26 JUNE
2018
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response __I Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
1.1 Please describe how a Sub- Post Office understands I do not believe this Post Office objects to the request to the extent that it
Postmaster (“ SRworts al
issue (detailed from the moment
that SPM picks up the phone),
how this is recorded and how
this is investigated (throughout
the various 1st, 2nd and 3rd
lines of support).
the word "issue" to mean a
bug in Horizon. If this
request intends the word
"issue" to have a wider
meaning then the scope of
this request goes beyond
the Horizon Issues and is
not agreed.
The means by which a
SPM may report an issue
request is out of scope
since Issue 1 concerns
how bugs, ERRORS or
defects have the potential
to cause apparent or
alleged shortfalls relating
to Subpostmasters’
branch accounts or
transactions.
For Post Office to
requires Post Office to provide information about how
SPMs report issues.
Post Office accepts that Issue 1 concerns "bugs,
errors or defects" that have the potential to cause
apparent or alleged shortfalls relating to
Subpostmasters’ branch accounts or transactions.
Fujitsu has supplied the following document
references in relation to request 1.1, 1.1(a) and
AC_151249965_1
POL00256155
POL00256155
RFI
Mr Coyne's Request
Post Office's Initial
Response
Mr Coyne's Response
to Post Office
Post Office's Response Pursuant to Paragraph 1
of the Fifth CMC Order
to Post Office will be known
to the Claimants and so Mr
Coyne can obtain this
information from his own
clients.
The processes for how
Post Office and Fujitsu
record issues and how they
are investigated through
the various lines of support
should be located in
documents and Post Office
will ask Fujitsu to provide
document references.
a. If a Peak/bug is
determined, how is the impact
considered and what is the
process or scheduling into the
development cycle and then
ultimately the code versioning
system?
b. When and how are
changes agreed through to
release management, including
the release notes for new
versions and which persons
these are shared amongst?
1.1(a) and 1.1(b) should be
limited to bugs that could
potentially create
discrepancies in branch
accounts. Subject to that
point, the answers to 1.1(a)
and 1.1(b) requests should
be located in documents
stipulate that ‘ issue’
refers to bug alone is
unreasonable as an SPM
would not know if an
error they encountered
was in fact a bug.
1.4(b).
To the extent that the Claimants are seeking more
information beyond that provided in the documents
below, then Post Office objects to the request on the
basis that (i) the scope of the request is not
understood and / or (ii) the requested information is
not necessary.
SVM/SDM/PRO/0875
END TO END APPLICATION SUPPORT STRATEGY
POL-0122492
SVM/SDM/SD/0004
Horizon Online 3rd Line Application Support Service:
Service Description
POL-0129558
SVM/SDM/SD/0005
Application Support Service (4th line): Service
Description
POL-0148637
SVM/SDM/SD/0007
Service Management Service: Service Description
POL-0148662
SVM/SDM/PRO/0018
Incident Management Procedure
SVM/SDM/OLA/0017
Operational Level Agreement HNGx 4th line support
POL-0128502, POL-0110230
POL00256155
POL00256155
AC_151249965_1
RFI
Mr Coyne's Request
Post Office's Initial
Response
Mr Coyne's Response
to Post Office
Post Office's Response Pursuant to Paragraph 1
of the Fifth CMC Order
SVM/SDM/PRO/0025
POST OFFICE ACCOUNT CUSTOMER SERVICE
PROBLEM MANAGEMENT PROCEDURE
POL-0146787, POL-0152874
PA/PRO/001
CHANGE MANAGEMENT PROCESS
POL-0073950, POL-0122492
SVM/SDM/PRO/1184
MSC MANAGED SERVICE CHANGE PROCEDURE
FOR POST OFFICE ACCOUNT
POL-0136725
SVM/SDM/OLA/3308
FUJITSU - ATOS HORIZON SERVICE
OPERATIONAL WORKING AGREEMENT
POL-0148882
CS/OLA/045
OPERATIONAL LEVEL CHANGE AND RELEASE
MANAGEMENT INTERFACE AGREEMENT
BETWEEN POST OFFICE LTD AND FUJITSU
SERVICES
POL-0069985, POL-0070483
SVM/SDM/PRO/1520
RELEASE MANAGEMENT STRATEGY
POL-0138750
CS/MAN/011_ PEAK USER GUIDE
POL-0032934
AC_151249965_1
POL00256155
POL00256155
RFI
Mr Coyne's Request
Post Office's Initial
Response
Mr Coyne's Response
to Post Office
Post Office's Response Pursuant to Paragraph 1
of the Fifth CMC Order
DE/PRO/015
INCIDENT / DEFECT MANAGEMENT PROCESS.
POL-0075416
SVM/SDM/SD/0023
POA Call Enquiry Matrix and Incident Prioritisation
POL-0148327
SVM/SDM/PRO/0019
BRANCH ISSUE MANAGEMENT PROCESS
POL-0143705
CS/IFS/008 Fujitsu Services / Post Office Limited
Interface Agreement for the Problem Management
Interface
POL-0146857
c. Is there a consolidated
complete release/version
chronology available for
Horizon/Horizon Online with
accompanying Release Notes at
final version?
Part 1.1¢ new request.
Fujitsu has provided a list of Release Notes.
Although the list does not contain the accompanying
Release Notes (of which there are 19,842) at final
version, if there are any in particular that you would
like to see Post Office will request these from Fujitsu.
1.2
Please describe how
bugs/errors/defects identified by
Fujitsu Services (“ dithe )
Post Office (“ B@’processed
if it is the case that this is a
different mechanism to those
identified through an SPM issue.
Post Office's position is that
the process is broadly the
same regardless of
whether an issue is
identified by FJ, PO or an
SPM. No further
documents or information
are required to comply with
Brdadigame” is not
extietlyame’ ;
therefore the request
stands. I do not believe
the processes employed
would be the same. For
example, it is not
envisaged that a Post
Post Office has provided document references
supplied by Fujitsu in response to request 1.1 which
detail how bugs/errors/defects identified by FJ or PO
are processed.
Fujitsu logs bugs/errors/defects that they identify in
the Fujitsu TSD incident management system.
When Atos log a call that is for Fujitsu (i.e. where a
AC_151249965_1
POL00256155
POL00256155
there further documentation that
might detail any specific
branches that were affected?
that would require Post
Office to carry out a
satellite disclosure
exercise. It should also be
noted that POL-0032853 is
a Fujitsu document and
one of the 100 technical
documents provided to Mr
Coyne. A further 110,000
such documents have now
been disclosed to Mr
Coyne and Post Office is in
no better position than Mr
Coyne or his clients’
instructing solicitors to
search those documents.
It also appears to be an
attempt to obtain
documents containing
information that could
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
this request by beyond that I Office back office SPM or PO has identified an issue) it is automatically
provided in response to employee who might note I transferred across to the TSD. Once a call is logged
request 1.1. an error would telephone I into TSD the process for resolution is the same.
the same helpline as an
SPM would.
a. What are “ offiffies” ? Part 1.2a new request. All of the KELs that have been provided by Fujitsu
and disclosed to the Claimants are headed "SSC.
Offline KELs" in order to avoid any possible confusion
with live KELs. The disclosed copies reflect a
snapshot in time of the KEL database which is a live
and changing environment. This is also the reason
why every KEL has the same date in the right hand
heading, being the date the copy was taken.
1.3 I In relation to POL-0032853, is This is a factual question Request still valid. Post Office objects to this request.
This is a request for disclosure not information. It
cuts across categories 1 and 2 of Stage 3 Disclosure
and is seeking to improperly expand the scope of
disclosure.
Class 1 was for reports and briefings (excluding
emails) produced by Fujitsu and submitted to
Category 1 or 2 Custodians regarding the nature and
extent of bugs, errors or defects (not limited to
software) in Horizon that had the potential to cause
branch accounts to be inaccurate.
Category 2 was for reports and briefings (excluding
emails) produced by Post Office and submitted to
Category 1, 2 or 3 Custodians regarding the nature
and extent of bugs, errors or defects (not limited to
software) in Horizon that had the potential to cause
branch accounts to be inaccurate.
AC_151249965_1
POL00256155
POL00256155
RFI
Mr Coyne's Request
Post Office's Initial
Response
Mr Coyne's Response
to Post Office
Post Office's Response Pursuant to Paragraph 1
of the Fifth CMC Order
potentially be tied to
individual cases. That is not
the purpose of the Horizon
Issues trial.
1.4
Regarding POL-0032932.doc,
what is the purpose of setting an
NB102 exception to F99 by Fu?
Post Office will ask Fujitsu
to explain the purpose of
setting an NB102 exception
to F99.
Satisfied that Fujitsu will
be asked to explain the
cause, awaiting further
information.
When there is an incident involving a reconciliation
exception in Network Banking which has been fully
processed, then the transaction needs to be set to
F99 to indicate that processing is complete.
Therefore, this is done for any transaction that
appears in a reconciliation report, once the resolution
is complete.
The reconciliation process document is
SVM/SDM/PRO/0012 RECONCILIATION AND.
INCIDENT MANAGEMENT PROCESS and describes
how reconciliation is carried out.
SVM/SDM/SD/0020 END TO END
RECONCILIATION REPORTING is the specifications
of the reports that are produced for the reconciliation
service.
The CCD that describes the contracted service:
SVM/SDM/SD/0015 RECONCILIATION SERVICE:
SERVICE DESCRIPTION.
POL-0032909
POL-0151930
POL-0134458
a. How often has [setting an
NB102 exception to F99]
occurred?
1.4(a) is a factual question
and Post Office would need
to interrogate the whole of
its business to attempt to
answer it because the
information is very unlikely
With regard to “ how
often” this js a valid
request. If it is answered
for example this is an
isolated incident that
impacted one transaction
Fujitsu currently "F99" 10,000+ transactions per week
across all NB102 associated reports (DCP and NBS).
AC_151249965_1
POL00256155
POL00256155
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
to have been pooled or in 2003, a different
collated for this particular inference can be gained
purpose. It should also be than if the answer given
noted that POL-0032932 is I is 10,000 transactions
a Fujitsu document (and each day for the last ten
one of the 100 technical years.
documents provided to Mr
Coyne). A further 110,000
such documents have now
been disclosed to Mr
Coyne and Post Office is in
no better position than Mr
Coyne or his clients’
instructing solicitors to
search those documents.
b. What is the cause of an 1.4(b) Post Office will ask The DCP report NB102 section 3 (Uncleared
‘ Uncléredsaction Fujitsu to explain the cause Corruptions) usually contains 100s if not 1000s of
Corruptions’ and how often do of‘ UncléBredsaction transactions per week (Kiosk transactions only).
{Uncleared Transaction Corruptions’ However, This is where there is a discrepancy on banking and
Corruptions] occur? “and how often do these
as 4 payment card transactions. To determine the exact
occur" is a factual question cra "
cause of any individual Uncleared Transaction
and the response to 1.4(a) . :
is repeated. Corruption, that particular occurrence would have to
be analysed. However, the most usual cause is for a
banking request or authorisation failing to reach its
destination, which is something that can have a
variety of causes. An example may be that a bank
may authorise a transaction, but that confirmation is
not delivered to the counter so the SPM believes that
the transaction in fact failed due to some issue.
1.5 Regarding POL-0032919.pdf, The relevance of this This request is required Post Office objects to this request.
the GoldenGate replication
between Oracle 10g and 11g
being aborted and resulting in a
number of branches reporting
request is not understood.
Transaction Corrections
are issued by Post Office to
correct transient
to effectively answer part
(b) of Issue 1 which is to
understand whether
Horizon did accurately
To the extent that this request goes to issue 1, which
is not accepted, it cuts across categories 1 and 2 of
AC_151249965_1
POL00256155
POL00256155
a. Please provide how many
times (and over what period)
“ Softfearés affecting
reconciliation and settlement”
have been reported?
b. Please provide how many
times (and over what period)
“ End-toA#® reconciliations
differences” have been
reported?
c. Please provide how many
times (and over what period)
“ Reconciliétioors” have
been reported and if these lead
to“ BeSness Incidents”
document and one of the
100 technical documents
provided to Mr Coyne. A
further 110,000 such
documents have now been
disclosed to Mr Coyne and
Post Office is in no better
position than Mr Coyne or
his clients’ instructing
solicitors to search those
documents.
Further, these are factual
questions and Post Office
would need to interrogate
the whole of its business to
attempt to answer them
because the information is
very unlikely to have been
4 pooled or collated for this
With regard to “ how
many times and over
what period” If it is
answered for example
this is an isolated incident
that impacted one
transaction in 2003, a
different inference can be
gained than if the answer
given is 10,000
transactions each day for
the last ten years.
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
cash declaration and stock discrepancies in branch process and record Stage 3 Disclosure as explained above.
reporting discrepancies, were accounts in order to restore I transactions. Further, Post Office remains of the view that this
Se eet coreouors sent the correct position. The response is required I appears to be an attempt to obtain documents
a result of the discrepancies and It also appears to be an to understand full circle containing information that could potentially be tied to
. attempt to obtain whether information was __I individual cases, which is not the purpose of the
which branches were affected by oan . " " .
the incident? documents containing sufficiently collected in Horizon Issues trial.
information that could the event of an error, to
potentially be tied to fix it. Therefore, where
individual cases. That is not I branch accounts were
the purpose of the Horizon affected, could and were
Issues trial. they identified and was a
correcting transaction
issued to rectify the error.
1.6 I With regard to POL-0032901: POL-0032901 is a Fujitsu Request still valid. Post Office objects to this request.
In response to request (a): Fujitsu does not record
reconciliation incidents in such a way as to allow
retrieval of incidents by such a category without
retrospectively carrying out detailed analyses. This
would require a disproportionate effort and cost.
In response to request (b): Fujitsu has advised Post
Office that such a report does not exist.
While POL-0032901.pdf relates to Horizon this report
is still run in HNG-X and the numbers below are from
the records Fujitsu now hold:
01/07/2017 - 30/06/2018: 162 APS Reconciliation
Error BIMS
AC_151249965_1
POL00256155
POL00256155
RFI
Mr Coyne's Request
Post Office's Initial
Response
Mr Coyne's Response
to Post Office
Post Office's Response
of the Fifth CMC Order
Pursuant to Paragraph 1
d. Please provide how many
times (and over what period)
“ rBitdrts” are produced?
particular purpose.
01/07/2016 - 30/06/2017:
Error BIMS
01/07/2015 - 30/06/2016:
Error BIMS
01/07/2014 - 30/06/2015:
BIMS
01/07/2013 - 30/06/2014:
Error BIMS
01/07/2012 - 30/06/2013:
Error BIMS
01/07/2011 - 30/06/2012:
Error BIMS
01/07/2010 - 30/06/2011:
Error BIMS
01/07/2009 - 30/06/2010:
Error BIMS
01/01/2009 - 30/06/2009:
Error BIMS.
125 APS Reconciliation
104 APS Reconciliation
39 APS Reconciliation Error
37 APS Reconciliation
42 APS Reconciliation
33 APS Reconciliation
69 APS Reconciliation
76 APS Reconciliation
15 APS Reconciliation
01/07/2017 - 30/06/2018:
01/07/2016 - 30/06/2017:
01/07/2015 - 30/06/2016:
01/07/2014 - 30/06/2015:
01/07/2013 - 30/06/2014:
01/07/2012 - 30/06/2013:
01/07/2011 - 30/06/2012:
01/07/2010 - 30/06/2011:
2096 BIMS
1208 BIMS
1773 BIMS
1020 BIMS
1130 BIMS
875 BIMS
1013 BIMS
1413 BIMS
AC_151249965_1
POL00256155
POL00256155
RFI
Mr Coyne's Request
Post Office's Initial
Response
Mr Coyne's Response
to Post Office
Post Office's Response Pursuant to Paragraph 1
of the Fifth CMC Order
e. Please provide how many
times (and over what period) the
“ Prolixmagement Process”
has recorded the potential for a
system or software error?
f. Please provide how many
times (and over what period) PO
has been notified of a
“ widespeeent” - as
determined by this document?
01/07/2009 - 30/06/2010: 3201 BIMS
01/01/2009 - 30/06/2009: 335 BIMS
Post Office objects to this request.
Fujitsu believes that it does not record problems in
such a way that would allow this to be determined
without retrospectively carrying out detailed analyses.
This would require a disproportionate effort and cost.
Post Office objects to this request.
Fujitsu believes that it does not hold collated
information that would allow this to be determined
without retrospectively carrying out detailed analyses
of all its communications with Post Office. This would
require a disproportionate effort and cost.
Furthermore, this is, in substance, a request for
documents and not information. Communication of
problems of this nature from Fujitsu to Post Office are
covered by categories 5, 6 and 7 of Stage 3
Disclosure.
AC_151249965_1
POL00256155
POL00256155
“ Batars / Not Data Errors”
a. Please describe what
“ work-aroumateé previously
been agreed between PO and
FJ in accordance with page 6
where “ ..inaccupaeyror was
not capable of being corrected
by the User before irrevocable
commitment of the cash account
in question...”
that Fujitsu should be able
to answer information
request 1.7(a) and Post
Office will ask Fujitsu to do
so.
information in respect of
Fujitsu providing a
response to information
request 1.7(a).
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
1.7 I In relation to POL-0032864.doc Post Office understands Awaiting further This request applies to the solution before the Impact
Programme 2005. Fujitsu believe that "work-
arounds" in this context refers to the ways in which
individual errors are recorded and that such
corrections would have been done with the
authorisation of Post Office via the method in use at
the time, e.g. OCPs. Fujitsu do not have a document
that lists all of the agreed "work-arounds" and to
retrospectively collate such information would be
disproportionate.
AC_151249965_1
POL00256155
POL00256155
RFI
Mr Coyne's Request
Post Office's Initial
Response
Mr Coyne's Response
to Post Office
Post Office's Response Pursuant to Paragraph 1
of the Fifth CMC Order
b. How many (and over
what period) were "Inaccurate
Cash Account (Data Errors)
recorded" and how many (and
over what period) were "Manual
Error Reports” issued?
c. How many (and over
what period) were "Repaired
Cash Accounts" or "Repaired
Transaction Data" identified? For
each, please provide the
Classification type at para 3.6.2
of document POL-0032864.
d. How many times has FJ
notified PO of "Widespread
errors" as defined at 3.6.4 of
document POL-0032864?
e. The document refers to
"Preventative code" - How many
times (and over what period) has.
such code been deployed?
f. How many times (and
over what period) have FU
provided reports to PO in line
with para 3.6.6.1, 3.6.5.3,
3.6.5.1, 3.6.5.2, 3.6.77
Requests 1.7(b).-(f) are
factual questions and Post
Office would need to
interrogate the whole of its
business to attempt to
answer them because the
information is very unlikely
to have been pooled or
collated for any particular
purpose. It should also be
noted that POL-0032864 is
a Fujitsu document and
one of the 100 technical
documents provided to Mr
Coyne. A further 110,000
such documents have now
been disclosed to Mr
Coyne and Post Office is in
no better position than Mr
Coyne or his clients’
instructing solicitors to
search those documents.
1.7(b) — (f) still required.
With regard to “ how
many times and over
what period” If it is
answered for example
this is an isolated incident
that impacted one
transaction in 2003, a
different inference can be
gained than if the answer
given is 10,000
transactions each day for
the last ten years.
Fujitsu is only able to search for records in relation to
the last three years and no such reports have been
recorded nor issued in this time.
Post Office objects to requests (c), (d) and (e).
Fujitsu has advised that while all incidents are
recorded the relevant system was designed to
manage individual operations not for statistical
reporting for when a particular action has been taken
by a Support Consultant. It would therefore require a
manual review and collation of data to provide the
requested information. This would be
disproportionate.
Furthermore, request (d) is, in substance, a request
for documents and not information. Communication
of problems of this nature from Fujitsu to Post Office
are covered by categories 5 and 6 and 7 of Stage 3
Disclosure.
Post Office objects to request (f). It is, in substance,
a request for documents and not information.
Communication of problems of this nature from
Fujitsu to Post Office are covered by categories 5 and
6 of Stage 3 Disclosure.
Post Office and Fujitsu do not hold the collated
information on the number of reports. It would
AC_151249965_1
POL00256155
POL00256155
Office dated 23 May 2016 to Mr
CE Burke and the failure of a
transaction to recover once the
system was restored. Can Post
Office please provide further
information on:
a. Why the transaction once
found, was recorded as a Lloyds
transaction and not TSB;
b. What was the reason or
cause (if it has been found) as to
why the restore process in
Horizon Online did not
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
therefore require a manual review and collation of
data to provide the requested information. This would
be disproportionate.
1.8 I Please describe in reference to Post Office understands Awaiting further Fujitsu assumes that this relates to the timings on the
the above document at page 20 I that Fujitsu should be able information pending old Post Office accounting system CBDB and the
what the effects are if the data is I to answer this information Fujitsu’ respsonse. timescale for getting changes into it before it passed
not transmitted within five request and Post Office will data onto other backend systems. Due to the age of
working days? ask Fujitsu to do so. the document and nature of the question, Fujitsu
have not been able to locate any relevant information.
1.9 I Please provide access to the This has been agreed and One day agreed at The first day of access has been provided. There is
Peak system(s) for inspection will be arranged pursuant present, second day to an open offer for Mr Coyne to attend for a second
with the capability to extract to the terms of the draft be arranged. day.
specific requested Order.
bugs/issues/peaks from the
system(s) for later review.
1.10 I In relation to the letter from Post New Request. Post Office objects to this request.
The letter to Mr Burke states that "the Transaction
Correction [was] showing against Lloyds and not
TSB", not the transaction. The request is therefore
misconceived.
AC_151249965_1
POL00256155
POL00256155
reference data being modified as
result of the “ Peak fix” - how
many times has a Live Peak fix
to reference data been made?
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
effectively recover the
transaction(s); and
c. Have there been or are
there any other known
occurrences where the restore
process has failed to recover
transactions and/or attributed
the wrong information (i.e.,
incorrect financial institution).
1.11 I How many times (and over what New Request. Post Office objects to this request.
period) has the PO Fraud Post Office does not presently hold information on the
Analysis Team” reported that a " " "
« technical” —_ Integnityfor number of "reports". It would therefore require a
“ Hoare” has been manual review and collation of this data to provide the
identified? requested information. This would be
. disproportionate.
Furthermore, this request is, in substance, a request
for documents and not information. Internal
communications of issues of this nature are covered
by category 2 of Stage 3 Disclosure.
1.12 I POL-0118364 refers to New Request. Post Office objects to this request.
Fujitsu have advised that reference data, like all parts
of the Horizon system, is subject to regular support
incidents being raised which require some form of
resolution. "Live Peak fixes" could therefore relate to
a number of situations that have no connection to the
Horizon Issues or the idea of bugs or errors in branch
accounts. This request is therefore too wide to be
properly understood and / or it is irrelevant to the
Horizon Issues.
AC_151249965_1
POL00256155
POL00256155
Horizon has (or that FJ apply) to
identify when an error/issue has
occurred and the potential
branch account impact?
from Fujitsu that there is no
such list of error codes, but
Fujitsu have agreed to
endeavour to translate
specific error codes upon
request.
see document
180622ECR1935 00-
03.doc
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
Even if the request were to be more narrowly defined
such that it was relevant, it is unlikely that Fujitsu
would already have collated the requested
information. It would require a disproportionate effort
to collate the relevant information in order to answer
this request.
2.1 Please describe how SPMs The generic part of this The request is intended SPMs were notified about the "Local Suspense
receive reports of active bugs or I request could be answered I to inform the answer to Account’ issue.
errors regarding the Horizon by Mr Coyne making Issue 2 and whether “ ‘ me
system. For example, were enquiries of his own clients. I Subpostmasters were Wes Oa of Poet Offs hee macs one ieee arose
SPMs notified about the * Lo Phost Office will seek to alerted to bugs, errors or confirm how SPMs were notified of the issue but has
Suspense Account’ problem, or defects within the
“ ReceimtsPayments answer the specific Horizon system. not been able to find relevant records so far.
- on example ( L8eapense ; :
mismatch’ issues (and any other Account" problem, or Post Office objects to the remainder of the request for
known issue within Horizon)? If “ ReceitsPayments the reasons already stated.
so, how? i on
mismatch” issues) by
4:00pm on 14 August 2018.
The broader "any other
known issue with Horizon"
would require Post Office to
carry out a satellite
disclosure exercise and, in
any event, it is clearly a
fishing expedition.
2.2 I Is there a list of error codes that I Post Office understands Jason Coyne — Please Post Office objects to this request.
This request was made by the Claimants’ Counsel to
the Court at the CMC on 5 June when the Claimants
asked for a list of all errors codes. The Court refused
to order this. Mr Coyne's request is a reformulation of
the same point.
AC_151249965_1
POL00256155
POL00256155
RFI
Mr Coyne's Request
Post Office's Initial
Response
Mr Coyne's Response
to Post Office
Post Office's Response Pursuant to Paragraph 1
of the Fifth CMC Order
Instead, the Court ordered Mr Coyne to produce a list
of error codes that he wanted to understand. Post
Office has provided the descriptions supplied by
Fujitsu in relation to the error codes identified by Mr
Coyne.
3.1
If it is the case that reports such
as NB102 recorded
reconciliation exceptions, what
information within this report
records the cause of such
exceptions?
Post Office understands
that Fujitsu should be able
to answer this information
request and Post Office will
ask Fujitsu to do so.
Response satisfactory,
awaiting further
information from Fujitsu.
SVM/SDM/SD/0020
END TO END RECONCILIATION REPORTING -
defines the NB102 report.
POL-0151930
SVM/SDM/PRO/0012
RECONCILIATION AND INCIDENT MANAGEMENT
PROCESS
POL-0128455
SVM/SDM/SD/0015
RECONCILIATION SERVICE: SERVICE
DESCRIPTION
POL-0134458
NB/HLD/O03_ NWB DATA RECONCILIATION
SERVICE HIGH LEVEL DESIGN
DES/GEN/SPE/0008
HNG-X BRANCH AND COUNTER REPORTS
POL-0153186, POL-0153528
DEV/APP/LLD/0179
COUNTER REPORTS LOW LEVEL DESIGN
POL-0153506
DES/GEN/SPE/0009
AC_151249965_1
POL00256155
POL00256155
RFI
Mr Coyne's Request
Post Office's Initial
Response
Mr Coyne's Response
to Post Office
Post Office's Response Pursuant to Paragraph 1
of the Fifth CMC Order
HNG-X RECEIPTS, SLIPS AND LABELS
POL-0148790
DES/GEN/SPE/0010
HNG-X BANKING, CREDIT/DEBIT CARD AND
ETOPUP RECEIPTS AND TEXTS
POL-0147186
SVM/SEC/PRO/0018
AUDIT DATA EXTRACTION PROCESS
POL-0215521
SVM/SDM/SD/0017
SECURITY MANAGEMENT SERVICE: SERVICE
DESCRIPTION
3.2
With regard to POL-0032855:
a. Para 1.0 - when was the
“totally manual" "Error notice
functionality" replaced by this
process?
(a). Post Office
understands that Fujitsu
should be able to answer
this information request
and Post Office will ask
Fujitsu to do so.
Part (a) response
satisfactory
As per the information shown on the front of this
document (DE/LLD/014) it was functionality
introduced as part of Release S80, also known as
“ InfRaktase 3 (Branch Trading Horizon
Enhancements)", the rollout to branches being
between July - September 2005.
POL-0081094
b. The document records
that“ — céméral accounting
function decides that it is
(b). This request is
outside of the scope of the
Horizon Issues as it relates
in relation to part (b), I do
not consider this to be
outside of the scope
Post Office objects to this request.
The Horizon Issues were the subject of much
negotiation between the parties and Post Office's
AC_151249965_1
POL00256155
POL00256155
acknowledgement that the
Horizon system is not perfect
and there has been deployment
of technical controls to reduce
errors, please describe:
should be noted that
documents containing this
information have been
disclosed to Mr Coyne and
Fujitsu have delivered an
introductory briefing on the
architecture of the Horizon
system to Mr Coyne
pursuant to paragraph 6(b)
of the Third CMC Order.
a. What these technical
controls are (referred to in
Defence paragraph 16);
b. For what reasons have
these technical controls been
triggered; and
(a) and-(b) Post Office
understands that the
answer to these requests
should be located in
document(s) and Post
Office will ask Fujitsu to
provide document
references.
(b) response satisfactory,
part (c) response still
required (wording
amended).
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
necessary to make some to a reconciliation process since adjusting the back-office reconciliation procedures/central
adjustment to the Branch that takes place outside of branch accounts, thereby I accounting function were not included in the agreed
Accounts” - how is this decision Horizon. impacts the Horizon Issues. This is because the Court directed
made? Subpostmaster and the that the Horizon Issues should be confined to issues
BRDB which is inside the I that concern the Horizon system and which (a) arise
boundary of Horizon on the parties’ generic statements of case, (b) can be
Response still required. resolved by IT expert evidence, and (c) require
limited, if any, evidence of fact.
Request 3.2(b) does not satisfy these requirements: it
cannot be resolved by IT expert evidence and it
would require significant factual evidence. This
request therefore relates to a subject matter that is
outside of the Horizon Issues.
41 Regarding the As a general point, it Jason Coyne — (a) and This request relates to part of a sentence in the
Defence which reads: “ desigritand technical
controls, when supplemented by the various
accounting and cash controls applied in branches...
Technical controls is not a defined terms and as such
these two documents are provided as an example of
the types of technical controls. To ask to provide all
documents relating to “ techoaretrols” as
undefined would be effectively to ask to explain every
technical control in place. Unless a more specific
request is forthcoming (e.g. technical controls relating
to X) these documents should suffice as an example.
The example of data integrity has been selected in
this case.
In relation to requests (a) and (b), please see the
following documents.
ARC/GEN/REP/0004 HORIZON DATA INTEGRITY
POL-0107388
ARC/GEN/REP/1229 HORIZON ONLINE DATA
AC_151249965_1
POL00256155
POL00256155
RFI
Mr Coyne's Request
Post Office's Initial
Response
Mr Coyne's Response
to Post Office
Post Office's Response Pursuant to Paragraph 1
of the Fifth CMC Order
c. How have the errors been
dealt with?
(c) Is not understood.
INTEGRITY
Post Office objects to request (c).
As to request (c), Horizon Issue 4 asks "to what
extent has there been potential for errors in data
recorded within Horizon to arise in (a) data entry, (b)
transfer or (c) processing of data in Horizon."
Request 4.1(c) goes beyond this by asking how
(unspecified) errors have been dealt with. This
request therefore relate to a subject matter that is not
covered by the Horizon Issues.
Furthermore, this question is too vague to answer. It
is not understood what "errors" are under scrutiny
and what is meant by them being “dealt with".
Even if these points could be better defined, this
question is disproportionately wide. It would require a
review of all Post Office and Fujitsu operations over
an 18 year period, significant disclosure and the
interviewing of dozens of potential witnesses.
4.2
In relation to POL-0032913, can
more information be provided on
the “ baaklatiscrepancies”
held by FJ?
Post Office understands
that Fujitsu should be able
to answer this information
request and Post Office will
ask Fujitsu to do so.
Response satisfactory,
awaiting further
information from Fujitsu.
Fujitsu has advised that the discrepancies described
are related to banking and payments reconciliation.
There were a lot of discrepancies identified in NB102
reports relating to kiosk transactions and there was
an issue that because they were not being cleared
down (ie set to state F99), then it was difficult to
distinguish new discrepancies from old ones.
These discrepancies would have had no impact on
Branch Accounts as they are related to Post Office's
reconciliation with Banks.
AC_151249965_1
POL00256155
POL00256155
led to the process outlined in
POL-0032939.doc (TPS —
EPOSS Reconciliation TIP
Transaction Repair) and how
many transactions have been
repaired?
that Fujitsu should be able
to explain what situation led
to the process outlined in
POL-0032939 (TPS —
EPOSS Reconciliation TIP
Transaction Repair) and
Post Office will ask Fujitsu
to do so.
The request for Post Office
to describe how many
transactions have been
repaired is a factual
question and Post Office
would need to interrogate
the whole of its business to
attempt to answer them
because the information is
very unlikely to have been
pooled or collated for this
particular purpose.
It should also be noted that
POL-0032939 is a Fujitsu
document and one of the
100 technical documents
provided to Mr Coyne. A
further 110,000 such
documents have now been
disclosed to Mr Coyne and
Post Office is in no better
position than Mr Coyne or
his clients’ instructing
solicitors to search those
documents.
reporting elements of
how many transactions
have been repaired have
been disclosed or are
likely to be found in a
technical document
therefore the request still
stands.
With regard to “
many” this js a valid
request. If it is answered
for example this is an
isolated incident that
impacted one transaction
in 2003, a different
inference can be gained
than if the answer given
is 10,000 transactions
each day for the last ten
years.
how
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
4.3 I Please describe what situation Post Office understands I do not believe the Fujitsu has advised that the transaction repairs were
missing mandatory attributes (in the receiving
systems) — particularly for Mails-based transactions,
and there was a process for manually correcting
these transactions before they were passed to Post
Office. This would have no impact on the Branch
accounts and no changes were made to Branch
Transactions — it affected information needed by back
end systems.
POL-0032939.doc relates to fixes made in TPS and
so have no impact on Branch accounts. The main
situation that led to the process was transactions
missing mandatory attributes and this sometimes
occurred with Mails transactions on old Horizon.
Such malformed transactions were permissible as far
as the counter and branch accounting were
concerned, but not complete enough for Post Office
back end systems.
Please also see:
POL-0032939
POL-0149393
Post Office objects to that part of the question that
requires it to quantify the number of repair.
This information is not needed because this topic
does not affect branch accounts.
Furthermore, Fujitsu does not presently hold
information on the number of repaired transactions. It
would therefore require a manual review and collation
of this data to provide the requested information.
This would be disproportionate.
AC_151249965_1
20
POL00256155
POL00256155
RFI
Mr Coyne's Request
Post Office's Initial
Response
Mr Coyne's Response
to Post Office
Post Office's Response Pursuant to Paragraph 1
of the Fifth CMC Order
5.1
Please provide a list of all data
sources outside of Horizon that
have led to discrepancies
between the external data
source and branch accounts of
which a comparison with data
inside Horizon is required.
This is not within scope of
Issue 5, which is how
Horizon itself compares
transaction data recorded
by Horizon against
transaction data from
sources outside of Horizon.
In any event, to answer this
question Post Office would
need to identify every
external data source that
feeds data into Horizon and
then review those data
feeds to see if there has
ever been a discrepancy
between any of them and
any transaction recorded in
any of 10,000+ branches
within the Post Office
network (presumably over
an 18 year period) in order
to then identify the data
sources that have
encountered a discrepancy.
To give this a sense of
scale, it is noted that
Horizon processes around
6,000,000 transactions per
day. The scale of this
exercise would be
enormous.
Wording amended.
Response still required. It
is expected that this is a
simple question to
respond to as an up to
date technical register
should be available.
Post Office objects to this request for the reasons
previously stated.
However Fujitsu has advised that the following
documents may be of assistance:
“ HorizonContexitiljpgtrates the current direct
connections and is cross-referenced to the
Application Interface Specifications on the AIS sheet
of the “ GBPunt Data Mapping.xisx’ file.
“ CTieké On Reports.zip” and “ PODG
Workbooks.zip” show indirect connections.
Copies of these documents will be provided via
Relativity.
5.2
Please describe what the
process is following the
discovery of a discrepancy
Post Office understands
that the answer to this
request should be located
Response satisfactory,
awaiting further
information from Fujitsu.
Fujitsu have advised that the process depends on the
discrepancy and what the sources are. If Mr Coyne
has any specific requests to make following his
AC_151249965_1
2
POL00256155
POL00256155
identified, what is the process for
determining whether a TC or
balancing transaction or should
be raised?
accounting process that
takes place outside of
Horizon and it is therefore
outside the scope of the
Horizon Issues.
outside of the scope
since TCs and Balancing
Transactions and/or
adjustments would affect
the Branch accounts
which are inside the
Horizon system.
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
between the two sources? in document(s) and Post review of the documents referred to in 5.1 above,
Office will ask Fujitsu to Post Office will ask Fujitsu to provide document
provide document references.
references. To the extent that this request expands into the
reconciliation processes conducted by Post Office,
then Post Office objects to this request for the
reasons stated in 5.4 below.
5.3 If report NB102 does not identify I Post Office understands Response satisfactory, The other reports are described in
all causes of discrepancies that the answer to this awaiting further SVM/SDM/SD/0020, which is referred to in relation to
between Horizon and request should be located information from Fujitsu. RFI 3.1 above.
transaction data sources outside I in document(s) and Post POL-0151930
of it, then what other reports or Office will ask Fujitsu to
sources exist to identify those? provide document
references.
5.4 Once a discrepancy has been This request relates to an I do not agree this is Post Office objects to this request.
The Horizon Issues were the subject of much
negotiation between the parties and Post Office's
back-office reconciliation procedures/central
accounting function were not included in the agreed
Horizon Issues. This is because the Court directed
that the Horizon Issues should be confined to issues
that concern the Horizon system and which (a) arise
on the parties’ generic statements of case, (b) can be
resolved by IT expert evidence, and (c) require
limited, if any, evidence of fact.
Request 5.4 does not satisfy these requirements: it
cannot be resolved by IT expert evidence and it
would require significant factual evidence. This
request therefore relates to a subject matter that is
outside of the Horizon Issues.
POL00256155
POL00256155
AC_151249965_1
22
any technical bridge or service
bridge meeting minutes (or
reasonable and
proportionate search for,
however should these
upon review prompt
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
6.1 Please describe what system Post Office understands This request is valid in Fujitsu has supplied the following references to
level logging and system events I that there will be respect of providing an documents that deal with system level logging and
are considered when documents which deal with I answer to part (v) of system events:
investigating shortfalls and system level logging and Issue 5 and the data
Transaction Corrections in order I system events and Post stored in the central data DES/SYMMHLD/0001
to investigate cause. Office will ask Fujitsu to centre not being an SYSMAN4 PASSIVE/ACTIVE MONITORING
provide document accurate record of SUPPORTING PLATFORMS (HNG-X)
references. ansactions entered on POL-0151777
" ranch terminals.
The phrase "when SU/HLD/002
investigating shortfalls and
Transaction Corrections in SYSMAN - NBX HLD (Horizon)
order to investigate cause"
refers to the Schone that POL-0076900; POL-0076988
Post Office might take to
investigate a shortfall. This
does not relate to Horizon
and is outside the scope of
the Horizon Issues.
6.2 I Please describe how often JSN This does not relate to This request is valid in Post Office assumes that Mr Coyne is referring to
checks were performed in the Horizon and is outside the respect of providing an Issue 6(e).
investigation of a scope of the Horizon answer to part (v) of This request is outside the scope of the Horizon
discrepancy/shortfall and what Issues. Further, it is a Issue 5 and the data Issues for the reasons provided in relation to Request
the results or records of factual question that would I stored in the central data 54 pr q
differences are? require Post Office to centre not being an
interrogate its business to accurate record of
attempt to answer it transactions entered on
because the information is I branch terminals.
very unlikely to have been
pooled or collated for this
particular purpose.
6.3 In relation to POL-0032915, are Post Office will undertake a I Response satisfactory, Post Office objects to this request.
This is a request for disclosure not information. This
AC_151249965_1
23
POL00256155
POL00256155
for _lost_ Discrepancies - G
Jenkins.pdf, how was it
ultimately decided iffhow FJ
should be “ corretitiegiata”
a. “ th®éases so far
identified there is one for
£30,611.16, one for £4,826.00
and the rest are all less than
£350" - are these losses or
gains?
b. How many FJ users are
able to adjust the Opening
Figures and BTS data?
Horizon and is outside the
scope of the Horizon
Issues.
?
outside of the scope. This
request is valid in respect
of providing an answer to
part (v) of Issue 5 and the
data stored in the central
data centre not being an
accurate record of
transactions entered on
branch terminals.
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
similar documentation) available I and then give disclosure of, I further questions, I shall request cuts across categories 1 and 2 of Stage 3
(page 31)? any technical bridge or request those at a later Disclosure (which do not extend to meeting minutes).
service bridge meeting date. Without prejudice to that point, Fujitsu has advised
0032915, that there are no separate minutes of technical
. bridges; the records are contained within incident
It does not agree to reports.
disclose "other documents"
as this request is too wide
and imprecise.
6.4 Regarding Correcting Accounts This does not relate to I disagree that this is Post Office assumes that Mr Coyne is referring to
Issue 6(e).
It was agreed that the discrepancies would be fixed in
POL SAP by FSC. Appendix 1 to the Claimants’
Responsive Note in relation to the Third CMC is a
merge of records from a conference call and a note
by Gareth Jenkins. In the first part on page 3 there
were 3 alternative solutions proposed. Solution 2
was actually adopted (but that was not noted in the
minutes and was probably decided separately
The“ ReceipisPayments mismatch” issue arose
in 2010. Post Office has made enquiries to obtain
this information but it has not been able to locate it.
Post Office objects to this request.
The request is not currently understood. Post Office
is making further enquiries as to what is meant by "to
adjust the Opening Figures and BTS data”. Until that
is understood Post Office cannot comment on this.
POL00256155
POL00256155
AC_151249965_1
24
RFI
Mr Coyne's Request
Post Office's Initial
Response
Mr Coyne's Response
to Post Office
Post Office's Response Pursuant to Paragraph 1
of the Fifth CMC Order
c. Is there an audit trail of a
decision being made by POL to
‘ offitae “ disttepancy’
and adjusting of the Discrepancy
account to align the decision in
POL SAP?
Post Office objects to this request.
This is a request for disclosure and not information.
Request 6.4 and 6.4(c) cut across categories 6, 7, 8
and 9 of Stage 3 Disclosure.
Category 5 - Reports and briefings (excluding emails)
produced by Fujitsu and submitted to Category 1 or 2
Custodians regarding necessary or recommended
measures for preventing/fixing bugs in Horizon that
might cause branch accounts to be inaccurate.
Category 6 - Reports and briefings (excluding
emails) produced by Fujitsu and submitted to
Category 1 or 2 Custodians regarding necessary or
recommended measures for developing Horizon so to
mitigate the risk that Horizon might cause branch
accounts to be inaccurate.
Category 7 - Reports and briefings (excluding emails)
produced by Post Office and submitted to Category T,
2 or 3 Custodians regarding necessary or
recommended measures. for preventing/fixing bugs in
Horizon that might cause branch accounts to be
inaccurate.
Category 8 - Reports and briefings (excluding emails)
produced by Post Office and submitted to Category 1,
2 or 3 Custodians regarding necessary or
recommended measures for developing Horizon so to
mitigate the risk that Horizon might cause branch
accounts to be inaccurate.
6.5
With regards to POL-
0032936.doc, what is the
definition ofa“ — evedt” and
what were the consequences of
Post Office understands
that Fujitsu should be able
to answer these information
requests and Post Office
Response satisfactory,
awaiting further
information from Fujitsu.
Fujitsu have advised that a red event is an event
written to the event log which is regarded as critical.
The event log is a standard Windows feature
(Microsoft documentation have fully documented this
AC_151249965_1
25
POL00256155
POL00256155
RFI
Mr Coyne's Request
Post Office's Initial
Response
Mr Coyne's Response
to Post Office
Post Office's Response Pursuant to Paragraph 1
of the Fifth CMC Order
a red event being raised silently
with no direct feedback to the
operator?
will ask Fujitsu to do so.
feature). To summarise, it is just a log to which
typically information events are written (just for
information), warning events (worth looking at but not
regarded as critical) and red events (which indicate
something critical has happened).
The meaning of red events does depend on context
but the idea is that something has happened that
must be looked at carefully.
a. Further, how were these
. sitthévents identified?
All unexpected red events are automatically
monitored. Automatically monitored means that all of
Fujitsu's platforms have software which looks at
events and flags any red ones unless they have been
specifically added to exclusion lists. Such automated
monitoring is described in the document
DES/SYM/HLD/0001 ‘ SYSMPassive/Active
Monitoring Supporting Platforms’
POL-0151777
6.6
In respect of POL-
0032912.docx, how many
occurrences of a Peak initiator
not being available or finding a
suitable replacement nominee
has led to a Peak not being
discussed at the Business
Impact Forum (BIF)/Peak
Targeting Forum (PTF)?
The first part of this request
("how many occurrences of
a Peak initiator not being
available... is"@ factual
question and Post Office
would need to interrogate
its business to attempt to
answer them because the
information is very unlikely
to have been pooled or
collated for any particular
purpose.
Request still valid. Peaks
are typically Errors/Bugs
within Horizon and if they
are not dealt with
appropriately may lead to
impact branch accounts.
d) removed.
Post Office objects to this request.
The request is disproportionate. To answer this
question it would be necessary to read through the
minutes of every BIF / PTF, and even then there may
be no confirmation of the targeted events ever
happening in the minutes.
AC_151249965_1
26
POL00256155
POL00256155
RFI
Mr Coyne's Request
Post Office's Initial
Response
Mr Coyne's Response
to Post Office
Post Office's Response Pursuant to Paragraph 1
of the Fifth CMC Order
a. How often do the forums
meet? The document states they
are to be held weekly each
Monday at 11:00am - was this
true in practice?
Request 6.6(a) is
unnecessary and is a
request for evidence which
is not appropriate.
There were 216 PTF meetings minuted between
January 2013 and 19 July 2018. Prior to that the
forum was referred to as RMF (Release Management
Forum and there were 47 meetings minuted between
January 2011 and August 2011, 87 meetings minuted
between October 2009 and December 2010, 156
meetings minuted between January 2007 and April
2008 and 46 meetings minuted between April 2006
and December 2006.
b. How many Emergency
PTFs have occurred?
Request 6.6(b) factual
question and Post Office
would need to interrogate
its business to attempt to
answer it because the
information is very unlikely
to have been pooled or
collated for any particular
purpose.
It is not possible to answer this request because the
minutes of “emergency PTFs/RMFs" are not recorded
differently from ordinary minutes.
i. Further, what were the
nature of these PTFs?
An "emergency" PTF would be held to discuss
something before the next scheduled PTF.
c. How are the Peaks to be
discussed at the forum decided?
Requests 6.6(c) and (d) are
factual questions which go
beyond the scope of Issue
6 towards specific cases,
which is not the purpose of
the Horizon Issues trial.
Without prejudice to that
point, Post Office
understands that the
answers to these questions
should be found in
documents and Post Office
Fujitsu has supplied the following document
references in relation to 6.6(c):
SVM/SDM/STD/2593
POL-0032912; POL-0136927
SVM/SDM/PRO/1520
POL-0138750
AC_151249965_1
a7
POL00256155
POL00256155
states: “ tDuiee potential
dynamic nature of the
Reconciliation Service, where
there is the potential for new
exception types to be generated
as a result of software errors
within new releases or reference
data, it has been agreed that
these procedures will be
documented outside of the
formal Reconciliation & Incident
Management CCD document
set.”
and Post Office would
need to interrogate its
business to attempt to
answer it because the
information is very unlikely
to have been pooled or
collated for this particular
purpose.
Request valid as it deals
with potential exceptions
which result from
software errors.
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
will ask Fujitsu to provide
document references
6.7 I POL-0032859.doc page 6 This is a factual question Request modified.
a. How many “ exception
types” have been identified to
present day?
Fujitsu have advised that no new "exception types”
have ever been identified by reference to the two
documents that list them:
* Horizon: NB/PRO/002 Network Banking
Reconciliation & Incident Management
+ HNG-X: SVM/SDM/PRO/0012 Reconciliation and
Incident Management Joint Working Document
The "exception types" listed in the first version of
NB/PRO/002 (Dec 2001) are the same as those listed
in the most recent version of SVM/SDM/PRO/0012
(Mar 2013).
POL-0063136
POL-0032909
AC_151249965_1
28
POL00256155
POL00256155
a. Please provide how many
times (and over what period) a
“ Reconciliaticnr is the result
of some system fault” that has
been determined as a software
or system fault.
b. Please provide how many
times (and over what period)
there has been “ Evidefiee
system fault [that has needed]
some corrective action”
c. Please provide how many
times (and over what period)
Business Incidents (as
described at 3.3.1) are reported
to“ Fufiténd Line Support
(SSC) for any system fault of
database adjustment”
d. Please provide how many
times (and over what period)
DBTN Incidents (as described at
3.3.1.3) are reported.
e. Please provide how many
times (and over what period)
Type E03, E04, E05, E06, E07,
£08, E09, £12, £13, £14, £21,
£23, £25, E26, E29, E30 (as
described at section) are
reported.
and Post Office would
need to interrogate its
whole business to attempt
to answer them because
the information is very
unlikely to have been
pooled or collated for this
particular purpose.
request is for information
about the
frequency/duration of
accepted Horizon system
faults/errors.
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
6.8 I With regard to POL-0032909: These are factual questions I Request still valid, this Post Office objects to this request.
Fujitsu has advised that their systems were designed
to manage individual operations not for statistical
reporting for when a particular action has been taken
by a Support Consultant.
This request would therefore require a manual review
and collation of this data to provide the requested
information. This would be disproportionate.
Fujitsu has advised that it does not hold this
information.
Fujitsu has produced an excel table which will be
provided via Relativity.
AC_151249965_1
29
POL00256155
POL00256155
accounts to modify or insert
data, is the purpose recorded?
Post Office and/or Fujitsu
were able to access
transaction data remotely.
Issue 10 concerns whether
Post Office and/or Fujitsu
were able to edit or delete
transaction data and Issue
11 asks if they did, did
Horizon have any
permission controls upon
the use of the facility/did it
maintain a log of such
actions and such
permission controls. None
of these issues involve
factual investigations as to
how many times these
facilities were used, if any.
Mr Coyne's requests in
relation to Issue 7 are
therefore treated as if they
had been made under
Issue 10 and/or 11.
Post Office understands
that the answer to this
request should be located
in document(s) and Post
awaiting further
information from Fujitsu.
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
f. Please provide how many This request is the same as 1.6c above.
times (and over what period)
APS Reconciliation Errors are
displayed within the APSS2133
report.
71 When FJ accessed branch Issue 7 concerns whether Response satisfactory, Fujitsu has supplied the following document
references:
DEV/INF/ION/0001
Archive Server Configuration (includes reference to
HNG-X BRDB Transaction Correction Tool audit data
sub point)
POL-0141243
DEV/APP/LLD/0142
Host BRDB Transaction Correction Tool Low Level
Design
POL-0032866
SVM/SEC/PRO/0012 Post Office Account User
Access Procedure
ARC/SEC/ARC/0003 HNG-X TECHNICAL
SECURITY ARCHITECTURE
DES/SEC/HLD/0004._ HNG-X AUTHORISATION
HIGH LEVEL DESIGN
DEV/APP/LLD/2952 Active Directory LLD design for
Windows 2012
DEV/APP/LLD/0028 ACTIVE DIRECTORY LOW
LEVEL DESIGN FOR HNG-X
AC_151249965_1
30
POL00256155
POL00256155
Transaction amendments
(including reversals and
balancing transactions) can be
identified for those which were
not carried out by the SPM in the
audit/transaction data/logs (i.e,
that the answer to this
request should be located
in document(s) and Post
Office will ask Fujitsu to
provide document
awaiting further
information from Fujitsu.
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
Office will ask Fujitsu to
provide document
references.
7.2 I Please describe what privileges Post Office understands Response satisfactory, Fujitsu has supplied the following document
and capabilities Administrators that the answer to this awaiting further references:
had in relation to Branch remote I request should be located information from Fujitsu.
access and the relevant in document(s) and Post ARC/SYM/ARC/0004
processes and procedures? Office will ask Fujitsu to HNG-X SYSTEM AND ESTATE MANAGEMENT
provide document REMOTE ACCESS AND DIAGNOSTICS
references. DES/SYM/HLD/0017
REMOTE SUPPORT ACCESS HIGH LEVEL
DESIGN
SVM/SEC/PRO/0012 Post Office Account User
Access Procedure
ARC/SEC/ARC/0003 HNG-X TECHNICAL
SECURITY ARCHITECTURE
DES/SEC/HLD/0004_ HNG-X AUTHORISATION
HIGH LEVEL DESIGN
DEV/APP/LLD/2952 Active Directory LLD design for
Windows 2012
DEV/APP/LLD/0028 ACTIVE DIRECTORY LOW
LEVEL DESIGN FOR HNG-X
7.3 Please describe how Post Office understands Response satisfactory, Fujitsu has supplied the following document
reference:
DES/APP/HLD/0020 Branch Database High Level
Design
AC_151249965_1
Et)
POL00256155
POL00256155
tool that allows transaction data
to be modified outside of branch.
Please describe how such
modification was audited, and
how the audit files are updated?
Further, how often such a tool
was used?
that the answer to this
request should be located
in document(s) and Post
Office will ask Fujitsu to
provide document
references, save that "how
often such a tool was used"
is a factual question that is
outside the scope of Issues
7,10 and 11.
awaiting further
information from Fujitsu.
With regard to “
often” this js a valid
request. If it is answered
for example this is an
isolated incident that
impacted one transaction
in 2003, a different
inference can be gained
than if the answer given
is 10,000 transactions
each day for the last ten
years.
how
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
is it flagged in some specific references.
way)?
7.4 I POL-0032939.doc references a Post Office understands Response satisfactory, Fujitsu has supplied the following document
reference:
DES/APP/HLD/0020 Branch Database High Level
Design
In relation to how such modification was audited and
how the audit files are updated, Fujitsu has advised
that:
The tool can only be used on data that has failed to
be delivered between the Branch Database
(previously Horizon) and the TPS system. This data
is quarantined within the TPS system until the
Transaction Repair tool corrects it. The correction is
made on the TPS database and cannot directly affect
the branch accounts in the Branch Database (or
previously, Horizon).
Once corrected the transaction data flows to
Credence and POLSAP.
The corrected data is stored in TPS for 36 days and
then archived on the TPS audit sub-point. Only the
copy of the corrected record is kept but, if necessary,
this can always be compared with the counter audit to
see what has been modified.
In relation to how often such a tool was used:
There is a master MSC every 12 months, each time
such a modification is carried out it is itemised as an
MSC related to the master MSC; however master
MSCs contain many various types of changes, to
determine the number that relate to this particular
modification type Fujitsu would have to carry out
AC_151249965_1
32
POL00256155
POL00256155
RFI
Mr Coyne's Request
Post Office's Initial
Response
Mr Coyne's Response
to Post Office
Post Office's Response Pursuant to Paragraph 1
of the Fifth CMC Order
analysis of all individual tasks on all master MSCs.
Whilst this type of action may have been taken by
SSC it would have been in the context of an individual
incident. All incidents are recorded but the system
was designed to manage individual operations not for
statistical reporting for when a particular action has
been taken by a Support Consultant. Fujitsu will be
able to answer questions on individual branch queries
where the data is still available.
75
In relation to‘ Operalitarual
version 7 December 2006 -
pages 9-13.pdf and specifically
“ ifftneduction of the new
Post Office Ltd Finance System
(POLFS) in Product and Branch
Accounting (PBA.) Chesterfield
means that the finance teams
can no longer adjust client
accounts on site.”
a. Can it be described what
“site means?
b. Can it be described how
the process worked before this
‘ chaargeWwhat it entails
now?
New Request.
In response to 7.5(a): "on site" refers to Post Office
FSC.
In response to 7.5(b): Prior to Transaction
Corrections, branches were required to manually
enter Error Notices into Horizon which were sent to
them on paper. Error Notices would be accompanied
by evidence (which would change depending on the
type of transaction that required correcting). These
were manually completed by the SPM (i.e. manually
entered on to Horizon). However, once the change
took place, then the Transaction Correction would be
issued via Horizon and the branch would be required
to accept then settle centrally.
AC_151249965_1
33
POL00256155
POL00256155
whatis the nature of the data
error to be repaired as per
section 3.4.3?
that the answer to request
8.3(a) should be located in
document(s) and Post
Office will ask Fujitsu to
provide document
understand that Business
and System Incidents are
the reporting functions
that record occurrences
and causes of shortfalls.
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
8.1 Please describe any reports This question is not Wording amended, Post Office objects to this request.
received by PO management understood and requires response still required. This is a request for disclosure and not information
that display the level of shortfalls I clarification. ‘4 .
and discrepancies arising from
Horizon bugs/defects. Please
provide copies of such reports.
8.2 I Please describe what dictates This request is outside the I do not agree this is out Post Office objects to this request.
when BIM and MER reports are scope of Issue 8, which of scope since both Post Office maintains that this request is outside the
produced and how often BIF and I asks "What transaction reports identify incidents scope of Issue 8. Without vejudioe to this point, the
PTF meetings were held and data and reporting and exceptions that re eect relatin to the fre Hen of BIF and PTE
whether meeting minutes (or functions were available had/have the potential to atin sis a a licate ‘dealt with in 6.6 above).
similar documentation) are through Horizon to Post impact branch accounts 9 PI . °
available for those. Office for identifying the which is within the scope I The request for meeting minutes is a request of
occurrence of alleged of Horizon. Request still disclosure and not information. It cuts across
shortfalls and the causes of I valid. categories 1 and 2 of Stage 3 Disclosure (which do
alleged shortfalls in not extend to meeting minutes).
branches, including a
whether they were caused re Bim and MER processes are described in detail
by bugs, errors and/or in these two documents:
defects in the Horizon SVM/SDM/SD/0015 Reconciliation Service: Service
system". Description
POL-0134458
SVM/SDM/PRO/0012 Reconciliation and Incident
Management - Joint Working Document
POL-0032909
8.3 In relation to POL-0032862.doc, I Post Office understands Request still valid. I Fujitsu has advised that this concerns old Horizon
TPS Reconciliation and Incident Management and is
the same as described in response to request 4.3
above.
POL00256155
POL00256155
AC_151249965_1
34
0032841 .doc Network Banking
Reconciliation and Incident
Management Processes:
a. How many times (and
over what period) are incomplete
states transactions noted?
b. How often were
comms/harvesting/ISDN/counter
issues the cause of Network
Banking system States 1, 2, 4,
5, 6, 7, 12, 13, 14, 15, E01, E02,
the scope of Issue 8 as it
goes beyond identifying the
data and reporting
functions available to
identifying the occurrence
of alleged shortfalls and the
causes of alleged
shortfalls.
In particular, request
8.4(b)(ii) asks for copies of
reports that relate to
“relevant branch accounts",
directly inform the answer
to Issue 8.
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
references.
a. What information is A Business Incident relates to the ‘ Symptochhot
contained within in a“ Business to the root cause of the exception.
Incident” 2
b. Is there a log of all Request 8.3(b) is outside System Incidents are logged as Peaks and/or
“ Busiiresdents” and the scope of Issue 8 as it MSCs.
Systeidents . goes beyond Identifying the Fujitsu has supplied the following document
data and reporting references in relation to request 8.3(b):
functions available to q “
identifying the occurrence PI/DES/008 TPS - EPOSS RECONCILIATION - TIP
of alleged shortfalls and the TRANSACTION REPAIR HIGH LEVEL DESIGN.
causes of alleged POL-0032939
shortfalls. Without
prejudice to that point, Post a soo TRANSACTION REPAIR TOOL.
Office understands that 7
Fujitsu should be able to
answer this information
request and Post Office will
ask Fujitsu to do so.
8.4 I With regards to POL- These requests are outside I This response would Post Office objects to this request.
Post Office's original response is repeated.
AC_151249965_1
36
POL00256155
POL00256155
(status Draft) - the_Helen Rose
Report_.pdf
a. Are there any other
known incidents where it is
suspected that a system crash
occurred and subsequently “
clerk may not have been told
exactly what to do.” [Page 2-3]?
the
b. What proportion of
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
£03, £04, E08, E09, £10,E11, which Post Office
£12 £13, E20, E21, £23, E26, understands to mean the
E27, £28, £29, £30, £34, £35, branch accounts of
E36, E37, E39: Claimants in this litigation.
That is not within the scope
i. After investigation when of the Horizon Issues.
had PO/FJ had to perform a
financial adjustment to rectify
system states?
ii. Please provide copies of
NB102 reports if they contain
transactions that relate to
relevant branch accounts.
8.5 I With regards to POL- Request 8.5 is outside the I do not believe this is out I Post Office objects to this request.
0032902.doc' _lin@rservices scope of Issue 8 as it goes I of scope, the response Post Office's original response is repeated
Reconciliation & Incident beyond identifying the data_I would enable answer to 9 P Pe .
Management - please provide a_I and reporting functions Issue 8 and identifying
list of how many "On Line available to identify the whether these indicated
Services Business Incidents" occurrence of alleged shortfalls in branches.
have been recorded (times & shortfalls and the causes of
dates). alleged shortfalls.
8.6 In respect of ‘ HoBaia New Request. Post Office objects to this request.
These requests are outside the scope of Issue 8 as
they go beyond identifying the data and reporting
functions available to identifying the occurrence of
alleged shortfalls and the causes of alleged shortfalls.
In particular, request 8.6(f) asks for a statement to be
explained which is a request for evidence.
AC_151249965_1
36
POL00256155
POL00256155
POL00256155
POL00256155
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
“ underlggsj [Page 3] and
indeed what logs are consulted
to confirm whether disputed
reversals are confirmed as part
of Recovery?
c. To what does “ Date”
refer and how was this
performed [Page 3]?
d. Why was there “ no
evidence one way or the other”
[Page 3] to identify whether a
system reboot did occur? Is this
typical?
e. Is it suspected that
utilising the “ DSRIQ logs” for
evidence in Court has previously
resulted historically in“ — givatg
a true picture.” Further, what are
the “ eaparts” that should be
acquired by the operational
team?
f. Can it be explained what
is meant by the following
statement“ know you are aware
of all the horizon integrity
issues... [Page 3].
g. Was the existing ARQ
report enhanced to make it clear
whether a Reversal Basket was
generated by Recovery or not
[Page 4]? Further, ifso, when
AC_151249965_1 37
RFI
Mr Coyne's Request
Post Office's Initial
Response
Mr Coyne's Response
to Post Office
Post Office's Response Pursuant to Paragraph 1
of the Fifth CMC Order
did this take effect?
h. ls it suspected that events
may have been “ misinterpret
when giving evidence and using
the same data for prosecutions.”
Has this been investigated?
i. Can the transaction data
and logs consulted and
referenced in this report be
provided for review to assist in
interpretation of the full issues
referred to in the document?
a
9.1
Please describe how often
counter error logs were reviewed
in the event of a reported issue
and if they were available to the
SPM for investigating issues?
Issue 9 asks "what
transaction data and
reporting functions (if any)
were available through
Horizon to [SPMs] for:
a. identifying apparent or
alleged discrepancies and
shortfalls and/or the causes
of the same; and
b. accessing and identifying
transactions recorded on
Horizon
Post Office understands
that the answer to the
question "were counter
error logs available to the
SPM for investigating
issues" should be located
in document(s) and Post
Response satisfactory,
awaiting further
information from Fujitsu.
Fujitsu have advised that while the term ‘ coenter
log’ is ambiguous, none of the reports available to a
Subpostmaster match the description ‘ coenter
log’
When investigating a reported issue a number of
different logs on the counter may be uploaded from
the counter to aid diagnosis — but these are not
specifically error logs. These logs would be accessed
as appropriate to the investigation in hand.
In our letter to Freeths dated 28 September 2017 we
explained that "The postofficecounterlog and
messagelog (the Logs) are sometimes used by
Fujitsu for, amongst other things, diagnostic
purposes. For example, when a postmaster reports a
technical issue to the Horizon Service Desk (HSD) it
may be appropriate to use these logs to investigate
the operation of Horizon in a particular branch. The
Horizon system does not use the contents of the Logs
for the purposes of branch accounting. The Logs are
held on the terminal for a period of 30 days, following
AC_151249965_1
38
POL00256155
POL00256155
RFI
Mr Coyne's Request
Post Office's Initial
Response
Mr Coyne's Response
to Post Office
Post Office's Response Pursuant to Paragraph 1
of the Fifth CMC Order
Office will ask Fujitsu to
provide document
references. However, the
remainder of this request is
outside the scope of Issue
9 as it goes beyond
identifying the data and
reporting functions
available to identifying the
occurrence of alleged
shortfalls and the causes of
alleged shortfalls.
which they are overwritten. Fujitsu can extract the
Logs from a terminal through a manual process which
takes approximately two hours.
The Logs are only considered in limited situations
where a postmaster alleges a technical issue which is
telated to the Horizon hardware and which would not
otherwise have been resolved. If your clients had
taised an issue of this nature in real time, then it
would have been possible to investigate the Logs as
necessary. This is however dependant on your clients
raising issues promptly and, in this regard, we note
that a number of your clients chose to conceal issues
rather than escalate them."
POL00256155
POL00256155
9.2
Please describe if Discrepancy
Reports have ever been
provided to SPMs and if so,
what was their purpose, what
replaced them and when?
Further, what receipts were
SPMs advised NOT to be
retained?
This request should be
answered by Mr Coyne
making enquiries of the
Claimants, particularly the
question "what receipts
were SPMs advised NOT
to be retained?" as this
appears to be an allegation
made by one of the
Claimants (Mr Coyne does
not refer to a document as
the source of his question).
It is Post Office who are
best aware of the agreed
process and procedural
documentation, this is a
request simply asking for
guidance on where it
might be discovered.
Request still valid.
Second Sight reported
that there are transaction
types where receipts are
not to be retained.
Post Office objects to this request.
It is not clear what is meant by Discrepancy Reports.
If Mr Coyne provides an example of the report he is
referring to Post Office will make reasonable and
proportionate enquiries of suitable individuals within
its business to provide this information.
Post Office's operations manuals have been
disclosed to Mr Coyne. As Second Sight have been
identified as the source of this issue, the request
should be answered by Mr Coyne making enquiries
Second Sight.
9.3
With regards to POL-
0032836.doc * EPBRS8to-
end Reconciliation Process For
Release NR2 - Incident
Management & Resolution’
This request is outside the
scope of Issue 9 (which
asks what data and
reporting functions were
available, not how many
a. Please provide how many
times were they used).
(and over what period) “ EPO}
b Eurther, this request would
This is not considered out
of scope in respect that it
is a request about reports
and/or data events wholly
relevant to Issue 9.
Response still required.
Post Office objects to this request.
This request is outside the scope of Issue 9 (which
asks what data and reporting functions were
available, not how many times were they used).
Without prejudice to this point, these requests are for
disclosure and not information. They cut across
AC_151249965_1
39
0032866.doc please set out how
many times (and over what
period) the "Host BRDB
Transaction Correction Tool" has
been used. Further, we
understand that process
BRDBC033 provides an audit for
that is outside the scope of
Issue 10 (which asks
whether Post Office and/or
Fujitsu had certain abilities,
not how many times they
were used).
goes directly to the
modification of data.
With regard to “ how
many times” this js a
valid request. If it is
answered for example
this is an isolated incident
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
reconciliation incidents” and require Post Office to categories 1 and 2 of Stage 3 Disclosure.
“ OBGMess incidents” have I interrogate its business to
occurred. attempt to answer it
because the information is
b. How many time (and over I very unlikely to have been
what period) were “ Hardware}, pooled or collated for this
comm. and software incidents particular purpose.
associated with the counter
systems reported to post office” ?
c. Also please provide a
description of the class of
documents (if any) which record
that data has been modified
(and/or transactions inserted) in
Horizon in circumstances that
may impact a branch’ acceunt
or transactional information.
10.1 I Please why branch account Post Office understands The current PO response I Fujitsu has supplied the following document
transactions rebuilds took place I that the answer to request to this question is not reference:
and if so, what is the process of 10.1 should be located in relevant to RFI 10.1,
informing the SPM or PO? document(s) and Post response still required. SVM/SDM/STD/0810
Office will ask Fujitsu to RMGA ENGINEER'S MANUAL FOR BASE UNITS
provide document
references. POL-0116724
10.2 I With regard to POL- This is a factual question Request still valid. This This tool exists in HNG-X only. This process has only
been used once, in relation to PC0195561, on 11-
Mar-2010.
Regarding confirming that BRDBC033 provides the
audit for this tool, as stated in DEV/APP/LLD/0142
section 5; one of Fujitsu's developers has checked
the code and confirmed that the statement in the
document is correct.
AC_151249965_1
40
POL00256155
POL00256155
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
this tool - please confirm? that impacted one
transaction in 2003, a
different inference can be I POL-0052866
gained than if the answer
given is 10,000
transactions each day for
the last ten years.
11.1 I For the One Balancing This request is beyond the I Request still valid. This SPM was notified by telephone.
Transaction that PO are aware scope of Issue 11 (which request relates directly to
of (Defence 57(3)) please asks what permission what permission controls
describe how SPM were made controls and logging are in place prior to
aware? systems were in place modification of data.
within Horizon in relation to
any facility to edit, delete,
etc. data from Horizon).
11.2 I Please describe whether the This question is not Wording amended Post Office objects to this request. This question is
Post Office or FU have a log of understood. It is not response still required. not understood. It is not understood who is said to
issues/events that were reported I understood what is meant have "reported" such and to whom.
where the discrepancy was by "events". It is not
known not to be caused by understood who is said to
human error. have "reported" such and
to whom.
11.3 I Please describe what would This request is beyond the I Request still valid. This Post Office objects to this request. The issue cited by
determine whether a branch was I scope of Issue 11 (which point goes directly to Mr Coyne (whether permission was granted to
informed or not of FJ carrying asks what permission whether permission was remotely modify branch data) is outside the scope of
out a modification/addition to controls and logging granted to remotely Issue 11 (which is "did the Horizon system have any
branch data. systems were in place modify branch data. permission controls upon the use of the above facility
within Horizon in relation to and did the system maintain a log of such actions and
any facility to edit, delete, such permission controls" emphasis added).
etc. data from Horizon).
11.4 I Please describe under what This request is beyond the I Request still valid. The Post Office objects to this request. The response
AC_151249965_1
ro
POL00256155
POL00256155
evidence/reports are provided to
a SPM with the Transaction
Correction. Are they informed of
what the specific transaction
was, or combination of
transactions in the event of there
information by making
enquiries of his own clients.
is meant by my “
clients” Request still
valid, response still
required.
own
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
circumstances branches were scope of Issue 11 (which “ passage” is directly I above is repeated.
told to pause usage of any asks what permission related to permission to
equipment whilst remote actions I controls and logging control the branch.
occurred. systems were in place
within Horizon in relation to
any facility to edit, delete,
etc. data from Horizon).
12.1 I KEL cardc1655P states as a This is a factual question Request still valid. I do Post Office objects to this request.
solution: “ f a counter is stuck in and, in any event, Dr not agree with Dr Worden Fujitsu h dvised that th f dofth
a‘ recovéeryp’ with the user Worden's view is that the that this question should yitsu have advised that the Pe y record of these
not being able to use the counter I experts should delay be delayed since Dr would 4 ae weal eae recone 2s
due to not being able to questions about specific Worden has not specified toonalysed to find similer oases This would be ave
complete recovery then it may KELs until they have done when he is willing to dispro tional .
be necessary to delete the a better review of KELs, review KELs. Props .
affected recovery records from and the questions can be
the grouped.
brdb_rx_recovery_transactions
table on the branch database.
However, this can ONLY be
carried out after being given
express authority to do so by
POL.” Please describe how
often such permissions were
typically given. Please describe
whether this solution was the
remedy for any other
KELs/issues?
15.1 I Please describe what Mr Coyne can obtain this It is not understood what I Mr Coyne's clients are the Claimants.
AC_151249965_1
42
POL00256155
POL00256155
RFI I Mr Coyne's Request Post Office's Initial Mr Coyne's Response Post Office's Response Pursuant to Paragraph 1
Response to Post Office of the Fifth CMC Order
being multiple causes?
15.2 I Please provide year by year This request is outside the Request modified, Post Office objects to this request.
data showing a) Transaction
Corrections issued and b)
Transaction Correction
resolution dates.
scope of Issue 15 (which
asks how did Horizon
process and / or record
transaction corrections).
response still required.
Post Office has already provided the information in its
possession relating to the volume and value of TCs
issued since 2015 and explained that this is the
extent of the data available.
Resolution dates are out of scope: Issue 15 simply
asks "How did Horizon process and/or record
Transaction Corrections?".
AC_151249965_1
43
POL00256155
POL00256155