POL00448292
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Assurance & Complex Investigations
Quality Assurance Framework Report
March 2024
POL-BSFF-104-0000251
Introduction
Introduction
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Vv
This report covers quality assurance reviews conducted in
February and March 2024.
It highlights common themes/shortfalls identified during the bi-
monthly quality assurance reviews undertaken by A&CI on
investigations conducted by the assured teams and makes
recommendations to address the same.
Individual scoring sheets for the files reviewed during the
reporting period have be shared and discussed with team
managers outside of this report.
Any training shortfalls identified during reviews have been
discussed with team managers and training/mentoring
offered/provided.
Analysis of investigative skills, knowledge and quality of
investigation files within the assured teams are summarised in
the report and trend analysis provided.
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Headlines
This Month
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Testing was completed in the Contracts Team, Network Monitoring Team and
the Network Resolution Team during this review period. No testing was
completed in the Branch Reconciliation Team as the team did not restart
investigative reviews insufficient time to be captured by this report, however,
this will be captured in the next review.
It is pleasing to see that there were no additional recommendations in the
Network Monitoring Team and the team are now in the main generally
complaint with all tests conducted as part of this review, with points lost for
minor errors and omissions.
It is also pleasing to see that many of the aged recommendations have now
been cleared during this review period.
While there are more recommendations than normal in the Network
Resolution Team, this is because the team have adopted a revised process as
part of Lottery exit programme which requires some amendments to the
strategy. The team should be commended for achieving their highest score to
date, demonstrating continued and ongoing progression. Well done to
everyone in the team with a particularly mention to team manager Tracy
Bannister who has been driver in getting the team to the high standards
demonstrated in this report.
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Definitions of priorities used in QAF reporting.
Definition
A recommendation is rated as ‘High’ priority when the Quality
Assurance review identifies material weaknesses in operational
processes or the non-adherence to operational processes which could
lead to POLs inability to evidence that processes have been applied as
designed with no gaps in record keeping.
IA recommendation is rated as ‘Medium’ priority when improvements in
operational processes and record keeping have been identified.
‘Changes applied as a result of these recommendations will strengthen
operational processes as well as providing assurance that processes are
working as designed.
A recommendation is rates as ‘Low’ priority where improvements could
Ibe made to processes and procedures to improve outcomes of
activities.
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No. Observation Recommendation Rationale Date of Ree. ‘Assured Team Response Antilpated sure Date
Various versions ofthe Postmaster IThe Poly sreviewed to ensure that To-ensure consistency of approach when conducting 2670372024 IThe centalreposkory for all PM palices are on the branch hub, however
support Policy - Accounting, Dispute _references in the Policy remain valid, _ reviews and transparency its important thatthe policy is POF copies are placed on the teams site for ease of reference, 3.2 version
Resolution in circulation. The T2/T3 Teams uptodate and reflects the latest approved approach and s now available on the teams site
site contains version 3.0. Version 3.20f {The Policy is updated on the T2/T3 Teams thinking nd that al references remain vali the policy willbe updated as per the yearly policy review which starts
the same policy is available on POL's The site to reflect the latest version of the every year in May and published in June. o Mitton and Tracy Marshall are
Hub: Policy, including the current De Minimus. [De Minimus ie. the upper value at which a deficit will be the owners of all PM policies
routinely considered for write oft operationally senstve The OM level changed between policy eviews from £500 to £1000,
[the version on The Hub refers to De _I Consideration s given to either redacting_ material and could have financial implications forthe
hinims as being £500.00, the De Minimus value recording inthe business if this igure isin general circulation, the amount referenced inthe policy isnot the DM limit. tis a two bullet
Potcy available on The Hub, or removing line of principles applied by Trige to determine ifa OM limit should be
enquiries conducted with The Network the Policy from The Hub. appied tothe case. The DM limit is purposefully silent s0 as tobe able to
Resolution Operations Manager indicate ex upor down depending on volumes / unt costs. Standard application in
RMMHOH thatthe current De Minimus i 1,000.00, e’spute resolution processes. However, Simon W annually reviews the SyERASH.
Ges. policy with Jo Milton. Simon has already noted to make amends to make
at Section 4.1 of the Policy under the this clearer by removing a monetary value. The next annval policy review
heading of Ter 2 (inal bullet point), there cycle begins in May, therefore this recommendation i already in progress
sa reference to Appendix .1, there fs no as part of annual reviews/controbs
Appendix 9.1 (suspect the reference
shouldbe to Appendix 8.)
he Lottery Team within Ter2 are ithe dedision to conducta focused review [The business & oxting ts arrangement with the National 726/0372024 IThe team are conducting full review of these cases, specficto lottery and
currently conducting a focused review as_Ishould be recorded, this could be achieved [Lottery and where a discrepancy relating to National Lottery complete T2 reports. Inaddition the team include wording inthe report
part of POL's ext from the National oy ether: is identified T2/73 are tasked with performing a focused that this review relates solely to scratchcards. The project team were also
Lottery. As such, the team are not investigation. tis important that this change in strategy in involved inthis process. As this isan exit programme we agreed to deal
conducting a full ier 2 review asset out in}3) A Lottery review specific policy making_Isuch cases fs recorded as without such a record, it appears wth cases in the sprit of our own process and didnot require a specific
the Postmaster Support Policy - clear what checks will and willnot be I that T2 are not compliant with their own policy and lottery policy asitisa short term programme. ‘The process we follow has
JAccounting, Dispute Resolution and the performed by the T2 Lottery Team, _Istrategy. been shared and agreed withthe project team who have also provided
current investigation strategy. euidance in how to deal with specific cases. The volumes have been lower
lor, than predicted and wil shortly cease, We worked collaboratively with all
other teams doing lottery investigations, who do not have separate policies
12) the Decision and Action Log fr Lottery or separate strategies 50 rejected option 1 recommendation as not
cases is updated to record the revised required. However, although the lottery dips have been inconsistent
ano) lapproached being adopted and the reason across teams, I will accept point 2 recommendation and we will start
2/24 why onty limited enquiries will be purse. putting the wording that i already inthe body ofthe lottery reports "this osjoa/20z4
review relates solely to scratch cards" and nate this in the decision and
action log.
POL-BSFF-104-0000251_0004
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a = = tte = erie [ Sect nt cone
[Unable to access/locate the Postmaster A hyperlink is provided in the T2/T3 [Currently and with a few exceptions, only those working in 26/03/2024 [Partially accepted/partially rejected there is not a drop down for this.
vcs
nano}
apa
scratch card transactions throughout the
report involving scratch cards
No reference in the report that Seratch
card Tool results are referenced backto
source data
lnvestigation report setting out how the
Joutput from the Scratch card Tool is
eferenced back to source data and how
lony source data is used for decision
making
essential that onty source data is used for decsion making
to avoid decision being made on false or misleading data
Joutputs.
The Horizon data is placed in an excel spreadsheet which adds up the value
of scratchcards, rather than manually adding up. Wording isin the report to
reflect this. However in addition , we can add a further sentence
Results from the scratchcards excel spreadsheet are compared against
-ource data and where both datasets reconcile no further verification Is
undertaken. In the event thatthe datasets do not reconcile then source
data is interrogated to identify the reason for the discrepancy and the
findings recorded in the report.
05/04/2024
POL-BSFF-104-0000251_0005
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Cteenaton == ato roty I Ones. eee Soret Tantated dor at
Sect Ion ag ek cone. Tea are rondo emporio cd ey en nd WSS ATW PTET [ORT Tce Soper BRE, nT ae Bw
frccompcion he decslonandocton fave bth he nvesigating fcr andthe mvstgston cson sn acionlogcompled howe te sue we the sport
neo rvewe bytne Manager ogartctimesechin emacs, lestfopntctaeng so why the effe fotoned nse dnt utd ep von wth ie comple DBA Scon
spurs tne Mange stored te era net egu ot ed tow cere fe wich ies snes bean cometed
Foor deve Decton sd Acton got ne Manager sold cof thatthe
completes bcm aa Acton og har ee sy te wilco einer nner sam ful reine te re
pled pros tosuhoning repo Inman do eet on repr tat oat hes Daag completed
neta patrepesttrocommendstion [opt sched by Line Manager ft seey acon npc the ie este cect von ae
ra tere the Dect ond acto Los not tomoded ts dmc waces been ected
ssn completed then te ep
feet sduor ey
vn
py yoann
POL-BSFF-104-0000251_0006
Recommendation
Rationale
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Icommunications with Postmaster via
Jwnatsape.
JwhatsApp messages not uploaded to the
case file atthe earliest possible
Jopportunity.
Jwhatsapp messages only visible to the
Jcontracts Advisor In the case and the PM
Jand not the wider case team.
MIKO]
718
lwhatsApp messages which are potentially
Jsisclosable, not being retrievable due to a
Joroblem with the Contract Advisor's
Phone.
lunti such time as POL isues further
leuidance on the use of WhatsApp when
Jcommunicating with Postmasters the
following protocols should be adopted:
lt) The use of WhatsApp should be
discouraged and communications with
lp routed via a POL email address.
12) Any decision to use WhatsApp when
Jcommunicating with PM to be authorised
lon a case by case bases by Head of
contracts.
[3) communication between Contracts and
the PM via WhatsApp must be restricted
ko a POL mobile phone.
4} communications between Contracts
land a PM via WhatsApp must be
Jdownloaded at the end of each working
land saved to the case fle,
(While WhatsApp does provide a useful means of
Icommunication, when used in an investigative setting it
Idoes present security, data governance, disclosure and
Investigation management challenges.
[security - While WhatsApp does provide end to end
lencryption, i the phone containing the messages is lost or
stolen, and particularly i the phone is nat password
protected, sensitive POL data may be compromised.
Data Governance - if the event that POL receives @ DSAR or
FOI request, the DPA team may need to search mobile
iphones to ensure respondent data is capture data.
Disclosure - There is an obligation in both civil and criminal
Investigations to retain and record all relevant material,
this includes communications on WhatsApp. Failure to
[comply with such obligations may expose Contract
IAdvisors to a potential charge of perverting the course of
justice.
Investigation Management - tis imperative that all
members ofthe wider case team have access to all relevant}
material in the case when making decisions relating to the
matter under investigation,
Sending and receiving electronic communications via a POL
lemail address would resolve many of the issues highlighted
Iabove and therefore, the use of WhatsApp should be
Idiscouraged.
12/03/2024
lUpdate (21/03/2024) - agree with the recommendation, although a wider
Jousiness use policy needs to be considered, Happy to adopt the following:
11)! have discouraged the use of WhatsApp and that email comms be usedI
Jas far as possible.
J2) The team will agree with me on its use.
}3) Communication are already restricted to 2 POL mobile phone and
Jpersonal phones are not used
4) A copy of any WhatsApp communications are kept on the ‘contact log
Jmaintained by the tear
21/03/2028
lwhite the conclusion is highlighted in the
[case resolution on dynamics and various
ldocuments can be identified in the case
to explain what has happened, the
ldescription of the case, on Dynamics, has
M08 [been left blank. Therefore, while looking
124 atthe Dynamics log forthe case, it can be
Jconcluded that the PM has been
reinstated and from what date, but there
is no indication of why the PM was
Jsuspended in the first place unless al the
Jattached documents are read.
ail relevant fields completed in Dynamics.
Following a case from inception to conclusion in Dynamics
s challenging. Failure to complete all relevant fields in
[Dynamics only exasperates these challenges and results in
the reader having to review numerous documents to
understand what has occurred in the case and why. This is
time consuming and can be avoid if al relevant fields are
fully completed.
12/03/2024
New case management reporting tool process in Dynamics being designedI
for the contracts team, part of which will hopefully pick up on this
Jcequirement. Aim to have in place by end of 4 with fll training to the
team on use and roll out in PX (2024/2025).
Jonce in place if any further work is needed to meet requirement then
lhappy totak through
30/04/2024
POL-BSFF-104-0000251_0007
Observation
Recommendation
Network Monitoring Team
Rationale
awn Quick/Alison J Clark)
Priority
Date of Rec.
Assured Team Response
Status of
Response
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Anticipated
Closure Date
No recommendations
in this reporting period.
POL-BSFF-104-0000251_0008
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November & December 2023 Scorecard
Network Monitoring
Points Available CAS-3282218 CAS-3223498 CAS-3250307 CAS-3209546 CAS-3152352_CAS-3266111
Initiating Investigation
Conducting the Investigation
Interaction with Postmaster (to Include Fact Finding Calls conducted with
Postmasters)
Case Closure
Total
Average Score Expressed as a Percentage of Maximum Score Available
Seo23 Ot]. No
10
POL-BSFF-104-0000251_0009
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[ase to answer, suspension of Postmaster
termination of the contract, While the
Jovidence packs and reports produced by
Jother teams
always practical to have a completely independent decision
maker, the segregation of duties wll go someway to
achieving this aim.
Recommendation Tracker
Tecammendaion Taste Wiaaty I baat thet Tn rs Tama
e_I couse oat
ew ae management oor to prot Oya bing dened
ne speingct new cssn Dyas everytine ease forthe conta tea ge of wich wile topekup onthe
linen casei tranatered tom anater [wasters rom one team tothe nex aes haere fequrement atone nlc by end of.
eam the Contras Team adopted laow te proes of the vestigation nis ly toad 2ejonne29 Opiate (08/0/28 -dluer now puts bck othe oof 4 aunaneas
revs Dynaniccatonumer. oduct ue shold th cate be chalengs/ speed
eres court ten. date (1/08 -stonrackthavein lc by en of wh ul
ring tothe team om use andra ot nF (2024/2025)
romaer Suppor Poy sets prin bend he wor he
cena Ten do
date (3/0/28) -revsdcae summary decion atonal and
Idocument storage being worked through (see note below) for
Jimplementation by the start of the new financial year, Plan is to
recon of how he cae ea neds Mtiartehnentersatardents tnetantentt moro stay, decon land etn reertonntea
fodalwthtsversicharevdenee [nteducton of mestanionsvaeey [Panes may ado erin eof enn ot beng azyor.02x fenton meter th team odes ha ty ato ge aejonnons
icollection, contact with key witnesses etc, be - wl [of a meeting with a postmaster) will be incorporated into this review.
samt
date (1/0) il on rack for deer bye of ancl yar (thse
rom dora
update (70/26) - reve cae summary, econ rata and
Jeccumert storage being worked tough senate blo for
‘e sonsandsubzavent ston mptemetation bythe sta ofthe ew nary, an to
oreo key decom mde ding heap tetera nsnranrnnnseasorsrenenninda morgoratesrtegy, declan logan esting report nate
tees teimestgston and educa ofan Actonad econ tg ne the estan Oia ten aajoaacasonsttont method ote enn ounertand what they wan og Ok >ayopnone
resting sctons tan oventocaergn att wy tn few fckowe ers esting wih postmaster wl be nerporated i thi review
ate (1/0) tl on rack for deer bye of ian year (thse
rom ora
ict romthe sewed that
contac Advars are concn tr
own ener and alding evence
ia tnd princi futsin th UK tha those
peat, Contaeseleicn ot th Icharged with making decisions on the outcome of
fnvestigationthe Contract Advisor then contacts Teo full the rle of Fickensac eater a atri longing conversations about hw ths would wok (noting the sigicant
fates econ asthe oeome so audentor making eins axedon_wsatlns ar indepnde’ of henvesaation poe aajearnona us chang ths wold cary) Inthe satin is note that sayoxneas
[Termination Decision Committee is being established who will be
responsible forthe deczion to terminate an Agreement.
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Recommendation Tracker
Oeeeration Tecommendaton Tatloate Trionty —] Date of Rec. I — SonmaryaT arsed Tar Remora Pogren towards inplaneniaton I Statusof I Anlcpated
Resporse_I Gosure Date
is okes sense but we woud need support tounderstand what an
Inter dew plan shoul! look ie and Include any Best practice advee
enauy/ac ining are covered Insulin etal to meet pdt 24/0/24): Mecting preparation note being developed fora
tne objectives ofthe terew/ivertgatin. K wil adhe consent method forthe team tounder and wha they wat i ge out
I le pdb carson al (csc investigator in identifying gaps in understanding/evidence lof a meeting with a postmaster, including the need that what we cover at
ipogthand comprerersivedscefinding — [niarvinw Fan (asezection Eo I and will encourage the investigator to consider possible I meetings should mirror the questions that are asked in our rationales. This I
pearisaea aes Fey hehe a investigator's Manual) is produced. The I ‘ences and what evidence is avaiable to 28/03/2023 I ven extends tothe meeting invite letters and being clear to postmasters euszam3
evidence that anintervew plans flnis dictate and shouldbe tana Ie /ungemin he possible dle onthe ares to cover (noting that the purpose of the meting oo
estaban face and ges the postmaster the opportunity olden nd
be etsed and recorded in Dyas.
date (13/03 ston rack fr deverby end of financial year (th se
from Pt onwards
Pca parien toe oy mit nnt ob charged and raped sarang het V2 nS cre
hereto team to how thsinvesigoton tem completing thelr action andthen handing the cae to
paincntntat Ithe next team leads to lack of ownership with no one
ndwidal having a comprehensive understanding of the
Semvce and oe See eflectvehondovers betwee” Isingle dedicated Case Manager tooverseeImatter under investigation. Ths slo approach to The new SA igh} iin the assurance document
wor] Seger Yfomsandconsnotrenting her lesan rom neptiont investigation the use of unrest deadlines tnked with 2oroejoas fRmmneersmmeeneets Ft enathrben ed ate ayox/nons
eo completion across the whole etallteam. Imanagement focus on quantity and throughput of cases es ee
I@xposes POL to risk of allegations of breach of CPIA 1996 Jexpeciation is co move the service level in ine with other schemes subject to approvel Dy
Volume of workrepulry sited 05 reason why romana er navrsedintadasreqrag eieioncfewna woke
utile CAS numbers forthe sme ate
including new CAS number fora BAV neue of rukipl CAS numbers makes extremely New case management reporting tool process in namics boing esgned
challenging to follow acase from inception to conclusion, jaaiienent Alntefecelipesbyendefat
7 hie kis acknowledged thatthe su of [tht one CAS number remains withthe IThischallenge i exasperated by the conveyor bet sofia sufoioost
multiple CAS numbers is being addressed,
[this work fin train and remains
unresolved atthe time of writing this
report
ease from inception to conclusion.
lapproach to investigations adopted by POL with each team
Icompleting thet own area of responsibilty before hand
tothe next team which inturn leads to slo working
Update (13/03) - still on track to have in place by end of 4 with ull
training tothe team on use and rollout in (2024/2025),
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Recommendation Tracker
Tecammendaion Taste otty I bso thet Tn Tawar Tamra TR
e_I couse oat
ro our ret ning nd Rtionale Docent Monitoring, feedback
es ben pode te tam mente op nove te corer and
Lines of enquiry pursed resting an fesoing bein ther decion We ave lanin pls prove ogangI
Jentry in the corresponding box in the Mi Iaving completed a line of enquiry anc Jcoaching, training to help the team.
ay nthe correspondng bor nth NM Hered tn tng nthe corespening [Risinparnt tht soon independent fhe WM ;
chest eet ee often not Cee Thox on the NM checklist, the Support Iteam (an Inquiry for example) were to review the case file
tcnomteom nonbert) what the e/a - roe ues prove supper standard wording foreach
[tonorscam members) what sthe I Iegversshourecord how ts nang [hat they couldundrstandthe otome ofeach ie of mieten [Mpa -temnatinpsatinnaptnteeiehnbaeiedion asyoaneas
cng nat tere maybe an user [essen tbe nvesiaton does Jenquryandhew hs impasonthe vera ese, och ine feng, woul gener errno ech nu ona
pentane van [Pe emer eprate aba hecho Rob?
nyo eve hs proces rng the Februny heck nn of
eeptte
ine Mager checks ofthe progres of he vestigation
ine monagershouonduetaquelty _Ianduponcompltonof the investigation ate essential © consideration wb gen on ow we quit ssre nth em
fteckottlesansshulecord that he_fensire sty corrland ht ny obsertons and jos cat tetany oa carer hat he fa rovewed on
eck has ben performed long wih any [ection proved arecaplured, Tis isa quay asiance s2yao7eas_ names togivethe uo of the Diet Update OF 8/03/2024» aovsurons
fareaectonmthe acy Pain” [eeckand ot performance manage. When 3 wort hos ested and cates wb set to nM at the endo March or
bynes fanagemen checker beonprormed hs shoe ering
otedy mean of eat noe n Dyas
pero ines nad out of he ter (nt i th PAST) noe ob
ncn handover of ae edo
cente enaveeteutetien Gi _ [clear so we're comfortable that when something is handed across it will be
comprehen review ony roe icak wah Tie tobe put nth the ever parent head,
Jontne27/aapmildthe contacts fotween the Cnt Team ad AST
Ithat relate to offers to pay received from ineffective communications between the Contracts Team uneabecta/ae = fworbshen With fe Lesre,Sinon Worley. Abeon Clara
forthe 13 Marchtosat working trough Hows nando oar
JPM. If no such procedure exists, then a Jand PAST is likely to result in missed opportunities to 19/01/2024 es * 31/03/2024
rocare spun place seting out how [eer finds det POL
therefore, this offer was not followed up the Contracts Team/PAST will respond to See arttron iinmowdte meus tan
(mcrae tn-jeaureanmeceeell amie ry dacion taken tocar thera tenms have been ranged nd
Inde withthe PM regerdng repayment eetaahataenomnenta tet “
Jand the full amount remains outstanding. os is -
a member of he avon management en or
Jewctve wihertofamitarse thenstwes ih pat
[Peper feel ratte recon ag eit srry tobe introdiced a pat of the Termination Deen
Rational Documents in excess of 50 pages catieana! peice opsite/hleh car tae aavaral ou? [Committee so then can have an overview of the matter as part of their
lng wth no Ect Suna few
[requiring the reader to read the whole bi ne ets ioicgial; petecttneyipaiyinesd & igi neceancne 19/01/2024 31/05/2024
report to gain an understanding of the
jvhole case.
Rationale Documents.
Jan Executive Summary allows management to familiarise
themselves witha case ina relatively short period of time
when just a high-level overview i requited.
Update (13/03) - executive summary document drafted for use stillon
track fr delivery
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Recommendation Tracker
‘Observation Recommendation Rationale Priority] Date af Rec. ] Summary of Assured Team Response/Pragress towards Implementation I Statusat I Anticipated
Response _I Closure Date
Team
asa general note agro that an indeoendent review of te evidences neded
noting tal and ) the
postmaster chalenged the decson withthe dean to terminate being upheld by
tne becson Review Pane (wnicn is chaired by a former postaster and has a
terme postmaster onthe pane
2) Al eelovare material uploaded to case fe.
proposals to introduce anew document management system to repiace the case
summary document which isa word document) whereby all documents thatthe
contract Advior nas been provided wl be uploaded toa SharePoint site relevant
to that aranen The decision rationales competed bythe Contract Advisor wil then
nciade a nypein tothe relevant folder onthe site (as wal a Individual
perinks to the documents referred ain the ratonaie 40 everything is stores
Hone place). wil retrospectively work withthe Contract Advisor to see that this
acne.
4) Allrelevant material uploaded to case
fle
2) Obtain a Ter2/3 report to include a KELI
check
cas.s019110 2) obtain a Tie2/3 report tolnclude a KEL check
[as anove, a Ter 2/3 report wil be requested if dscrepancy related, Horizon checks
are conducted as pat of Tier 2/3 review. Again though wl request tat is
3) Alloutstanding lines of enquiry to be
concluded
Breach in continuity of evidence.
done torts branch
4) An independent review ofthe evidenceI
tncictetbfenceinn tie ‘available and the decision to terminate
5) i outstanaing tines of enquiry tobe concludes.
agree there 3 need toresure tata actions have been osed down and
revospectvely wore wits tne Contact Adviser to see tat tis is done,
No Tier 2/3 report obtained ‘hie contract there is ack of evidence on the case fle and outstanding
5)if folowing a review ofthe evidence 2#f enauiry. The decison to terminate appears to rely
No KEL check availabe inthis case a conclusions IPeavll on the account of the O and not evidence, As such, 1701/2024 Ie) an independent review ofthe evidence salable ad the decison to shat
jer ter ee eanered + yaa Jreached that the original decision is safe, then action is commenced to se¢
suction es ed i ri nh ten
lunsafe, then restorative actions are taken. We need to separate a decision to terminate a postmaster's agreement with a
6) flowing review ofthe evidence avaiable inthis case a conclusion
reached that the orginal decion was ursate, then restorative actions ae taken
7) To ensure the Independence, transparency and good governance of dedsions
[> terminate «contract, such deision ae taken by pane
wi be introduced as part the Termination Deciion Commitee
ict 08/02/28 Team ited to identity evidence of aleged admission onthe
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Recommendation Tracker
Recommendation
Priority
Date of Rec
“Summary of Assured Team Resporse/Pragrass towards Implementation
Status oF
‘Anticipated
Closure Date
[The version on The Hub refers to De
Minims as being £500.00.
Enquiries conducted with The Network
Resolution Operations Manager indicate
[that the current De Minimus is £1,000.0.
lat section 4.1 ofthe Policy under the
heading f Ter 2 (final bullet point), there
is reference to Appendix®.1 there is no
IAppendix 3.1 (suspect the reference
[should be to Appendix 8.2),
[The Policy i reviewed to ensure that
references inthe Policy remain valid,
[The Policy is updated on the T2/73 Teams
ite to reflect the latest version of the
Policy, including the current De Minimus.
Consideration is given to either redacting
the De Minimus value recording in the
Policy available on The Hub, or removing
Ithe Policy from The Hub.
[To ensure consistency of approach when conduct
reviews and transparency itis important thatthe policy
up to date and reflects the latest approved approach and
thinking and that al references remain valid
De Minimus Le. the upper value at which a deficit will be
routinely considered for write off is operationally sensitive
material and could have financial implications for the
business if this figure i in general circulation,
‘570372024
[The central repository forall PM policies are on the branch hub, however
POF copies are placed on the teams ste for ease of reference, 3.2 version
Isnow avaliable on the teams site
[The policy will be updated as per the yearly policy review which starts
every year in May and published in une. Jo Mion and Tracy Marshall are
the owners of all PM policies
[The DM level changed between policy reviews from £500 to £1000,
[The amount referenced in the policy i not the DM limit ts two bullet
line of principles applied by Triage to determine if a DM limit should be
applied tothe case. The DM limit is purposefully silent so as tobe able to
Jnex up or down depending on volumes / unt costs. Standard application in
dispute resolution processes. However, Simon W annually reviews the
policy with Jo Niton. Simon has already noted to make amends to make
[this clearer by removing a monetary value. The next annual policy review
cycle begins in May, therefore ths recommendation i already n progress
fas part of annual reviews/eontrols.
30/06/2024
[The Lottery Team within Tier are
[currently conducting a focused review as.
part of POL’ ext from the National
Lottery. Assuch, the team are not
[conducting a full Tier 2 review as set out
in the Postmaster Support Policy -
IAccounting, Dispute Resolution and the
[current Investigation Strategy.
[The decison to conduct a focured review
should be recorded, this could be
achieved by ether:
1) A Lottery review specific pliey making
clear what checks will and will not be
performed by the 72 Lottery Team,
2) The Decision and Action Log for Lottery
cases is updated to record the revised
approached being adopted and the reason]
ny only limited enquiries willbe pursed.
[The business is exiting its arrangement with the National
Lottery and where a discrepancy relating to Nationa
Lottery is identified 72/73 are tasked with performing a
Hocused investigation. Its important that this change in
strategy in such cass is recorded as without such a record,
It appears that 2 are rot compliant with their own policy
land strategy.
26/03/2024
[The team-are conducting a Tull review ofthese caren, specific to ottery
land complete T2 reports. n adltion the team include wording in the
report that this review relates solely to sratcheards. The project team
wore also involved in this process. As this is an ext programme we agreedI
to deal with cases inthe spint of our own process and did not require 2
spect lottery policy a tis a short term programme, The process we
Jotiow has been shared and agreed with the project team who have also
provided guidance in how to deal with specific cases. The volumes have
been lower than predicted and wil shortly cease. We worked
colaboratively with ll other teams doing lottery investigations, whodo
not have separate policies or separate strategies, s relected option 1
recommendation as not required. However, although the lottery dips
have been inconsistent across teams, I will accept pont 2recommendstionI
and we will start putting the wording that is already inthe body of the
lottery reports “this review relates solely to scratch cards" and note this
the decision and ation log
05/04/2024
Unable to access/iocate the Postmaster
ISupport Policy and Investigation Strategy
las referenced inthe T2/T3 investigation
report.
[A hyperlinks provided nthe T2713
Investigation Report template to the
Postmaster Support Policy and
Investigation Strategy.
[access controls tothe Postmaster Suppor
Policy and investigation Strategy is set so
that anyone with the link can access the
[Garrently and wah a few exceptions, only those working in
}72/73 have access tothe investigation Strategy. Asa result
anyone reviewing the investigation fle ether now orn the
future outside of 12/13 will not be able to access the
Investigation Strategy
36/03/2024
silly accepted/partialy rejected there isnot drop down for this
[AM confirmed touse option reject.
[accepted
IThe policy s held onthe branch hub central repository anda POF version
Jon the Ms Teams Tie 2 site,
[The central repository for all PM polices are on the branch hub, however
POF copies are placed on the teams ste for ease of reference, 3.2 version
Is now avaliable on the teams se
Rejected
[Acing the hypertink of the investigation strategy would confuse
Postmasters. The investigation strategy underpins inks to the offical
Postmaster Accounting Dispute policy V3.2
Adding the hyperink has been discussed previously with A&C! (Oct 2023)
land we agreed not to include the link in the report as & would confuse
P's, we agreed to add the strategy paragraph into the report, with the
strategy document for internal use stored inthe teams files for reference,
whichis where it can be viewed,
POL-BSFF-104-0000251_0014
POL00448292
POL00448292
Recommendation Tracker
Sbsewaton Tecommendaton Tatiorate ionty I Date ofRec Tasso Tear Tow
[crater ard Toatn use orecnaie [an exanations provided nthe nthe nave of warapareney and in oalconesit TEVOTAORA _ owes daa sus and altace othe nani ae, sno ve
scratch card transactions throughout the investigation report sting out how the_fssentl that nl Source data usedfor decison making he Haron datas placed nan excel spreadsheet which ad the
feport iohing sath carts tout tom the Scatchard Tools tavoiddeebion beng mae on fae o misleading data hate ofseratcheards, rather thn manual dng up. Wording inthe
feerenced back tosourcedata and how outputs epor toretiect ths, However in adtion, we canada further sentence
No etorenceinthe report that seatch only source datas wed fr dean suits fom the sratehcards excl spreadsheet are compated against,
esol res arereterencedbock to. [making source data and where both tae econcte no further verfeaton en
orc data tndertaken nthe event that the datesets do ot ence then sure
tas interrogated oer the reason forthe dscrepany andthe
finaings recorded inthe eport.
ahveidd ore
communication, when used in an investigative setting i
unttsuentine as POLissues futher I RE retentscury data governance, lsu and
guidance on the use of WhatsApp when I'™“°st¥ - -
communicating with Postmaster the
emmuncating wan Postmaster th I uy wh Watspp dos rove endo od
Jenevoton. the phone containing the messges ios or
sole, nd partes the phone ot password
prover intrersbatd de eect sath don may coon
peel om usenet dae (21/03/2028) - gre withthe recommendation, although wider
——— Data Governance - if the event that POL receives a DSAR or Jbusiness use policy needs to be considered. Happy to adopt the following:
Foirequest, the DPA team may need to search moble 2) have discouraged the we of WhatsAp and that ema comms be used
whatsapp messages only sible tothe 7) Any Secon use WhatsApp when’, [phones to ensure respondent data is capture data fs ora possible
{Contracts Advisor in the case and the PM wr pote ase i Tend 12/03/2024 }2) The team will agree with me on its use. 21/03/2024
an not the wider case team ae rele Dscosue-Thereis an obligation noth cian crim 5) communication are already restricted toa POL mobile phone an
ovestgations to tetain and recor alrlevant materi thi persona phones are not wed
whatsanp messages which ae potent <smuneaton betwen Contacte ana Ue communications on Whatspp. Fare to comply 6) copy of any WhatsApp communications are kept onthe ‘ontac og
[disclosable, not being retrievable due to a I) Communication between Contracts ant th such obligations may expose Contract Advisors to a Imaintained by the team
02 ing via Whatshpp must be ested . .
pesewah cena maton potential charge ofprvering the course of ists
4} Communications between Contracts eats Ghote obttnoae 7 tis haniessrer) ‘evan
indarmiviawhatsarpmustbe I Imatrainthe case when ling dections eatng tothe
sownioaded atthe endo ach working Iateranthe case when malig decisions relating tothe
Jand saved to the case file, =
sending and receiving electronic communiations via FOL
wie the oncasionisghighted inthe
case resolution on dys and various
documents canbe dentiedinthe case New case management reporting tool process in Dynamics being designed
Jesslain what has hppened, the se igs demand laa forthe contracts team, part of which wil hopeful ick on hs
~ Irequirement. Aim to have in place by end of Q4 with full training to the
Dymamie only exasperates these challenges and ess in peters bint rerio aee
be [Al felevant fiekds completed in Dynamics. Ithe reader having to review numerous documents to 12/03/2024 “ 30/08/2024
ee ee once in ple tan further work is needed tomeet requirement then
enstted and rom what date, but tere fatetieces) ; hoppy otakthrough
is no indication of why the PM was .
suspended inthe st place ules althe
staened documents rere.
POL-BSFF-104-0000251_0015
Observation
‘Summary of Recommendation in Previous Month(s)
‘Summary of Assured Team Response/Progress towards
POL00448292
POL00448292
“Anticipated
while the REM check form
Is uploaded to Dynamics, it
Iappears to serve as an
Jevidence gathering tool
Jand not a report.
therefore, the reader is
left to draw their own
Jconctusions (which may
laitfer from those reached
by the 10). ttalso requires
the reader to have a
[detailed knowledge and
understanding ofthe data
to enable them to
Interpretate the same.
JA report template is produced in which the 10 provides
2 plain language commentary on the lines of enquiry
lbeing followed, their findings from each enquiry and,
how this lead to the next enquiry. The report should
[conclude with the 10 providing their conclusions on the
Imatter under investigation and recommended next step,
JAn investigation report isthe 10's opportunity to set out
the facts of the case, identify key evidence, provide the
reader with an assessment ofthe evidence and make
recommendations on the next step. Failure to provide
[an investigation report means that the reader has to
reconstruct the investigation themselves by trawiing
through al the material available and for them to reach
their own conclusions. While there are occasions when
this approach maybe justified it is generally not a good
use of resources and should be avoided,
Tab to be added to the Rem Check Template which
details all the checks that form part of the rem check.
Also summary tab to be added to explain next actions,
Update AC 08/02/24- the tab will be added when this
work starts again once the source data is accessible by
the end of Jan 24. Update OF 08/03/2024 - Tab added
to Rem Check Template and proactive work restarted.
27/10/2023
Reconciliation nme
No investigation Strategy
Production of an investigation Strategy.
Hthis is a requirement under Chapter 5 - Roles and
Responsibilities of the Investigator Manual
JAn investigation strategy has been discussed with CM
lwho has indicated that because of the nature of work
Jconducted by the team, the team conduct the same
Investigation forall cases. Ithas, therefore, been agreed}
that a generic strategy can be produced and used for ll
Icases and that in the event that the 10 decides to
[deviate from the strategy due to the unique nature of a
particular case then this will be recorded in the Decision
Jand Action Log along with a clear rational for the
[deviation
Proactive Stock Investigations were temporarily paused
whilst a decision was made regarding adjusting Stock
Holdings. Now that it has been agreed BRT will continueI
this work but only review a reduced timeframe to allow
Postmasters to access thelr own data, this action will be
picked up again. Update - AC - 08/01/24 - There isa
plan now to allow the stack team within BRT to access
the source data for a2 year review period. This should
be resolved by the end of Jan 24. Update OF
08/03/2024 - All raw data available to whole team and,
proactive work restarted
30/11/2023
tis not always clear from
the case fle why an
Investigation is being
Jopened. Further searches
under different CAS
numbers relating to the
Isame branch sometimes,
but not always, provide a
clue as to the reason why
an investigation has been
Jopened.
A clear reason for opening the investigation using the
loneumonic JAPAN is st out in the Description boxon
the Activity Pane in Dynamics.
It should be clear to all from the case file why an
Investigation has been opened. When opening an
Investigation the Investigator should be mindful ofthe
pneumonic JAPAN and ensure that the investigation is:
Justified
Jauthorised
Proportionate
Jaualtable
Necessary
Failure to set out the reason for opening an
Investigation can lead to challenges under Article 6 HRA.
[fo be explored further on how we can introduce
appropriate wording to be used
}24/01 CM - Once the source data training has taken
place by end of Jan 24, Proactive work will be
relaunched in Stock Team this will include training
around detailed description being added to the
lDynamics case. OF to send AM a copy of the template
to be used to ensure it captures all requirements
Update OF 08/03/2024 - Template was sent to AM and
confirmed and feedback explains It matches
requirements and proactive work restarted
31/12/2023
May colette
In 6 out of the 7 cases
sampled had no REM
Icheck Template uploaded
lo the case file.
JA REM Check Template is utlised in 2 100% of
investigations and uploaded to the case file.
JA REM Check Template is the standard investigation
template used by BRT and is stipulated requirement as}
per E3.1 of the investigator's Manual. The template
provides a strategic direction and uniformity to the
Investigation work conducted by BRT.
This should be happening - additional training will be
Jeiven to ensure this take place
24/02 CM - Proactive work has been on hold until we
could ensure Source Data could be accessed, This action
wil happen moving forward, Update OF 08/03/2024 -
em check template created an confirmed by AM.
{raining has been given to proactive team to ensure
understanding
30/11/2023
POL-BSFF-104-0000251_0016
Observation
‘Summary of Recommendation in Previous Month(s)
‘Summary of Assured Team Response/Progress towards “Anticipated
POL00448292
POL00448292
Closure Date
Raw reports upload to
Dynamics as evidence.
However, itis often not
clear (to non-team
members) what purpose
the report serves and
without a degree of
analysis by an
appropriately trained
person whether the report
supports or undermines
the investigation.
Having completed a ine of enquiry/conducted analysis
the findings should be entered in the REM Checklist,
recording how this finding impacts on the investigation
land whether it supports or undermines the
investigation.
itis important that if someone independent of BRT (an
Inquiry for example) were to review the case file that
they could understand the outcome of each line of
Jenquiry and how this impacts on the overall case.
[consideration willbe given on how we quality assure in
this team
24/01 CM - This will be added to the summary tab of
the Rem check. Update 08/03/2024 -Stock rationale
Jdocument has been updated to include all
recommendations from AM. Proactive work has
restarted
30/11/2023
It is noted on several cases
inthe dip sample that the
Investigator telephones
the PM. A brief note is
Jentered into Dynamics
hich lacks detail and the
Jonly way to understand
what was said during the
Iconversation isto listen to
the recording in Puzze
The recording is nat always
Jeasy to locate and istime
Jconsuming to listen too.
Having listened to the
recording it is noted that in
Jone case the IO undertook
to conduct follow up
laction. This action either
did not take place or ifit
Idid, the action and the
Joutcome was not recorded
in Dynamics.
All points covered in a telephone conversation are
Jsummarised and captured in Dynamics.
IWhere the 10 undertakes to follow up on an action
Jduring a cal, that follow action take places and the
Joutcome of the same it captured in Dynamics.
Jwhite a recording of a telephone conversation is
Jexcellent evidence, the listening of calls is not the most
effective way of assessing the value of the evidence
Javalable. Therefore, in addition to the recording the
call an 0 should provide a brief summary setting out all
the matters that where discussed during the call
Including those that point away from the investigation.
Post cal the 10 should evaluate what was sald during
the call and seek to follow up andor corroborate what
lwas sald during the telephone conversation
Additional training will be given inthis area
24/01 CM - When the Source data training has taken
place by end of Jan 24, this action wll be added to the
relaunch and training delivered to Proactive Team.
Update OF 08/03/2024 - Phone call template has been
created by myself to ensure all detals of a phone call
are captured and added to the dynamics case
30/11/2023
POL-BSFF-104-0000251_0017
‘Summary of Recommendation in Previous Month(s)
POL00448292
POL00448292
‘Summary of Assured Team Response/Progress towards “Anticipated
Implementation
Investigations complete
and root cause of issue
Identified and problem
resolved. However, there
Is no report on fle
explaining what lines of
Jenquiry have been
Htoliowed and how these
lead to the resolution of
the problem.
Jas there is no report on
file, it follows that there is
no Decision and Action log
Jon file as this is currently
Jembedded in the closure
report.
IWhere an investigation leads to the identification of the
Joroblem and the discrepancy/issue is resolved then a
short report is produced explaining the lines of enquiry
{rollowed and how these led to the resolution of the
IThe Decision and Action log must be completed in all
Inthe interests of transparency and to protect Support
JAdvisors from allegations of malpractice, itis important
that a record is kept to explain why an investigation
lwhich has not lead to the recovery of funds/a sanction
I2pplied is kept and maintained.
lAccepted- Out of Zof the 4 cases dipped this month,
[cas-3110304 the branch gain was offset the following
HP, by a branch debit discrepancy and a TC.
lcas-3089878 -A debit discrepancy was offset the
fotiowing TP by a gain and a TCto offset.
Noted there should be a report ite attached to the
Jdynamics case for full transparency and a reminder wil
be issued to the team,
Noted A&C! will check in this round of testing before
the end of March, note use current cases not
retrospective at 12/13 stage ofa discrepancy review.
Ws changed the anticipated closure date to
31/02/2024 to reflect A&CI comments in column N
Jagici 12/03/24 - Testing complete and report lite
attached to cases completed after 22/1/24, therefore,
action closes as implemented.
alleged confessions by
PI's of misappropriation
lof POL funds captured
verbally only and not
recorded in sufficient way
Jas the confession could be
offered in evidence in
lwhatever venue,
during a mecting witra PA they admitted to misappropration
or Pot funds, note should be made of what wae said and te PM
nted to sign tre note
Ja tiepnone cals to PMs shouldbe recorded ia Pure! thus
capturing any admision made,
lt. cali receved froma PM and therefore, not automaticaly
recorded via a Pure, a note ofthe teleanone conversation should
le made imedately folowing thecal using the temp ate
provided in the investigator's Manual and saved tothe ase fie
[consideration shouldbe given to sending an erate the Pet
frotowing sun cals, thanking ther forthe cal andi te ema
stating, during tis cal you said that POL funds nave been ved or
lowing any subsequent meetings with the PM, whien must be
recorded, the admission must be proved in granular deta, now
much money, when was this, what did they do with the money,
were was tne money transferred to, now vas ts taster
enacted, way did they de ths, what was ther intention,
If admissions of wrong doing are not captured in an
Jevidential format, at the time the admission is made,
then such admissions may be lost or later
Iwithdrawn/denied.
Loss of key evidence, such as an admission, can lead to
Jcases being lst (in whatever venue) and/or reputational
Jdamage and it not being possible to recover POL funds.
Jal admission must be probed in granular detail and
Jcorroborated, An admission must never be the only
piece of evidence.
grote rere nod forthe Contre Avior to conssoy
fost conversations win pesrnasiesandwhere as admision
do onsro ni recorded corey (sng Puzzle to) would
ee nervous eis to be the lef te Contract Advisor [wh make
Isecerinston as towhecraraposimasarhas beached re
Jreomen:)soac a seeurty iesignorsandimerogace a postmaster
[raga meesing endronmers nor ask tha ey ign stamens Tas
ices melee PACE yo emironnent
fv aso nee do be mind haa ranch Asurance vis, wher
soximastermay be suspended, sinkslla staat expesence whieh
fray hove anime on wnat te postmase sas
Proposat
s) oral being introduced note team wth utes sto when
Jse(onditunaie ose how coeaptre te cls consent ond
kenzempersncoul).Conderion uo tobe gen to sharing record
Jt ene conversation with tbe postmaster atari har en pace
>) Any admisions or sussciono lege crnial acy obo
Jurdate 13/03. Pusze now ued by lhe eam Sil ned to work
oigh how te conten an be shared wh ne pore
Juda 35/02/24, Oacuson with ARC regarding sharing record with
Peximaser pent meting which willbe shared wth the eam. Acton
row isiemenced
POL-BSFF-104-0000251_0018
Observation
‘Summary of Recommendation in Previous Months)
Rationale
‘Summary of Assured Team Response/Progress towards
Implementation
POL00448292
POL00448292
RERETTTARTETT TOT
uploaded to the case file at
the point of collection,
Muttiple items of relevant
material uploaded to the
case file ina matter of a
few minutes, which
suggests that material is
being stored on the 10's
local drive and not on the
case file
Evidence only uploaded to
the case file after the PM.
has been terminated.
only evidence that the
Jcase team intends to rely
upon uploaded to the case
ile with no other material
uploaded to the file.
Failure to comply with the
requirements in Appendix
F of the investigator's
Jal material gathered during the course of an
investigation, or generated by the IO themselves must
be uploaded to the case file atthe point of collection, or
if not practical to do so, as near as practicable
thereatter.
JA sub-folder structure designed within case fle in order
that material can be separated between evidence on
lwhich the case team are seeking to rely and other
materia
Failure to comply with the disclosure obligations as set
lout in Appendix Ff the investigator's Manual may
result in the following
Icases either unable to proceed or Decision Makers (in
lwhatever venue being unable to make a determination.
IMiscarriages of Justice.
Reputational Damage.
Allegations that the 10 perverted the course of justice
Decisions (in whatever venue) being overturned.
ICompensation being paid to those impacted
cat heté with the team on the 29 January 2024 to talk
through document storage
Proposal isto introduce a new document management
eystem to replace the case summary document (which s
currently a word document) whereby alldocuments that,
the Contract Advisor has been provided will be uploaded
to. SharePoint ste relevant to that branch. The decision
rationales completed by the Contract Advisor will then
include a hyperlink to the relevant folder on the ste (as
wel s individual hyperlinks tothe documents referred to
in the rationale so everything is stores in one place)
wi cest this witha live case and then review how it has.
gone at our next team meeting (29 February 2024) with a
view that it willbe rolled out by the end of March (start to
use rom P3 2024/2025)
Update (13/03) - stil on track fr introduction for end of
March Live cases currently being tested (and working
wel) and al cases willbe managed this was from Apri
onwards
[Update 19/03/24 implemented with eect 20/03/24
31/03/2024
Muttiple items of relevant
material uploaded to the
case file ina matter of a
Htew minutes, which
suggests that material is
being stored on the 10's
local drive and not on the
case fle.
Evidence only uploaded to
the case fle after the PM.
has been terminated.
IAll material stored in one central case file (nt local
drives) which is visible can be accessed by all teams who
are party to the investigation
evidence uploaded to fle retrospectively undermines
Ithe provenance of the evidence and degrades the
Jcontinuity. This in turn can lead to the admissibility of,
levidence being challenged and may result in key
evidence being lost (regardless of venue),
I the whole ofthe investigation file isnot visible to al
Jteams then this may result in work being repeated,
decisions being made without a full and complete
understanding of al the facts.
IActions being missed (sipping through the gaps) 35 2
result of a team believing another has completed or wi
Jcomplete an action,
call hela withthe team on the 29 January 2028 to talk
through document storage.
Proposal is to introduce a new document management
system to replace the case summary dacument (which isa
word document) whereby all documents thatthe Contract
[Advisor has been provided wil be uploaded toa SharePoint
site relevant to that branch. The decision rationales
completed by the Contract Advisor will then include a
lypertink tothe relevant folder on the ste (as well as
inividual hyperlinks tothe documents referred to inthe
rationale so everything is storesin one place)
Wit est tis witha tive case and then review how it has
gone at our next tear meeting (29 February 2028) with a
view that it wil be rolled out by the end of March start to
use from Pa 2024/2025)
in ation to this the team (again on the 29/01/24) have
been reminded about the importance of uploading to
bynamics atthe time and not atthe end
update (13/03) still on tack for introduction for end of
haarch. Live cases currently being tested (and working well)
and al cases will be managed this was from Apri onwards
Update 19/03/24 Implemented 20/03/24
31/03/2024
2
POL-BSFF-104-0000251_0019
Observation
‘Summary of Recommendation in Previous Months)
Rationale
‘Summary of Assured Team Response/Progress towards
Implementation
POL00448292
POL00448292
Management review is
Jzeneric and simply states
thatthe manager has read
the report and agrees the
Hindings. This approach
provides no assurance that
the manager has actually
read the report or
provided any evidence of
Joverview and scrutiny.
Note -this isa repeat of
recommendation RIO8
lwhich was closed as
implemented 26/05/2023,
IThe manager should confirm that they have read the
report and provided specific rationale as to why they
believe the findings of the investigator are correct and
lwell founded. See section 11 of the investigator's
Manual for further guidance on what should be included}
in Manager's review.
Failure to provide specific feedback and confirmation as
to why the manager believes the recommendations of
lhe 10 are correct undermines the credibility of the
management review and therefore, the investigation
pracess as a whole. Which in turn may lead to Decision
Makers questioning the thoroughness of the
Investigation and undermine the Decision Maker's
Iconfidence to make robust determinations resulting in
poor outcomes.
Noted, will need to consider how this feeds into the
Joutputs from the Termination Decision Committee,
{Update (13/03) - narrative now increased to support
the decision setting out why the decision meets the
requirements as set out in the relevant policy
[document (particularly the suspension and termination
policies). This will be evidenced in any rationales from
March onwards
lonce the Postmaster Contract Termination Committee
are live (April 2024 onwards) this narrative willbe
captured in the committee meeting notes and the
Jcommentary added to the decision rationales)
31/05/2024
Postmaster contract
terminated due to breach
lof contract. No supporting
Tier 2/3 report. As a
result, there was no KEL
Icheck performed nor
Iconfirmation that Horizon
was not a contributing
Hactor in this case.
In cases involving branch discrepancies no Postmaster
contract terminated without a supporting Ter 2/3 (oF
Jagcl Transactional Analyst) report.
IThe Common Issues Judgement places an obligation on
POL to demonstrate that Horizon was not a contributing
actor when considering taking action against a PM
relating to a branch discrepancy. The way POL
Idemonstrates compliance with this obligation is the
Jcompletion of a Transactional Analyst report. Without
Jsuch 3 report, POL is unable to demonstrate that
Horizon was not a contributing factor in the branch
Jdiscrepancy and any termination and/or recovery are
potentially unsafe and are lable to challenge.
It needs to be noted thatthe postmasters agreement was
not terminated due to discrepancies, instead it was the
lacmitted) action that they had used over £200k of Post
ortice money to fund improvements on the retall side
[Given the admision a Tier 2/Tier 2 report was not
requested, however this is noted and a Ter 2/Tier 3 report
will be requested for any termination decision that
involves a branch discrepancy (whether POL knows the
[cause or not) This has been implemented with immediate
errect.
Please note though that alldecsionsto terminate can be
challenged by the postmaster, inthis case the decision was]
challenged and the decision to terminate was upheld by
the Decision Review Panel
as.ct 08/02/28 - The recommendation relates to2/3rds of
the cases inthe dip sample and not just one case. Assured
Team invited to revs this recommendation and
recommendation reopened by ABC
Update (13/03) -not sure what addtional action needed
here, as noted a Tier 2/Tier 3 report willbe requested for
any termination decision that involves a branch
discrepancy whether POL knows the cause or not)
29/02/2024
a
POL-BSFF-104-0000251_0020
‘Summary of Recommendation in Previous Months)
‘Summary of Assured Team Response/Progress towards
Implementation
POL00448292
POL00448292
Closure Date
No direct correlation
between findings
recording in rationale
Jdocuments and supporting
Jevidence.
Each piece of evidence given a unique reference
number/ink
lwhen producing Rationale Documents the 10 provides
the reference number/hyperlink to the piece of
levidence they are seeking to rely upon in support of the
point they are making
JAny evidence that undermines the case and/or assists
the other side specifically referenced in the Rationale
Document and brought tothe attention of the decision
maker and the other side
Jwithout a unique reference number/link, iis
Icnallenging forthe decision maker to appreciate the full
weight of evidence available to prove a particular point.
Failure to highlight and bring to the attention of the
Decision Maker and the other side material that
undermines the case or assist the other side, exposes
the 10 and POL to legal challenge, reputational damage
Jand may lead to a miscarriage of justice.
JAs above - Proposal isto introduce a new document
management system to replace the case summary
Jdocument (which is currently a word document)
whereby all documents that the Contract Advisor has
been provided will be uploaded to a SharePoint ste
relevant to that branch, The decision rationales
Jcompleted by the Contract Advisor will then include a
hyperlink to the relevant folder on the site (as well as.
individual hyperlinks to the documents referred to in
the rationale so everything is stores in one place)
will test this with alive case and then review how It has
gone at our next team meeting (29 February 2024) with
2 view that it will be rolled out by the end of March
[start to use from P 2026/2025),
Update (13/03) - stil on track for introduction for end,
lof March, Live cases currently being tested (and
working well) and all cases will be managed this was
from April onwards.
lUpdate 19/3/24 Implemented 20/03/24
31/03/2024
Icase spanning several
months and occasionally
years, with no recorded
management
review/oversight.
Management conduct at least @ monthly review of all
lopen investigations and record that a review has taken
place on the case Action and Decision log in accordance
with the Assurance Section ofthe Investigator's Manual
https://poluk sharepoint.com/sites/invesitgatorsManual
\sitePages/Assurance.aspx
Failure to provide support, guidance and oversight to
10's can lead to the 1O becoming blinkered, lines of
Jenquiries that ought to be pursued not being followed,
Jwhich in turn can lead to poor investigative outcomes.
Support already given to the team on an ongoing basis,
with weekly calls to talk through any branches they are
dealing with
A8.c1 08/02/24 - Evidence in support of response
requested,
{Update (13/03) - need to understand what evidence I
can provide here, these updates form part of a weekly
catch up I have with each team member. Need to
balance capturing evidence against my time needed by
me to write everything up. Support on the evidence
needed here would be appreciated,
Update 19/3/24 Advice provided by A&C! and to be
implemented with effect 20/3/24.
29/02/2024
2
POL-BSFF-104-0000251_0021
‘Summary of Recommendation in Previous Month(s)
‘Summary of Assured Team Response/Progress towards “Anticipated
POL00448292
POL00448292
David
Southall
Icommunications with
Postmaster via WhatsApp.
IwhatsApp messages not
uploaded to the case file at
the earliest possible
Jopportunity..
IwhatsApp messages only
visible tothe Contracts
JAdvisor in the case and the
PM and not the wider case
lxeam,
IwhatsApp messages which
are potentially dsclosable,
not being retrievable due
toa problem with the
Icontract Advisor's phone.
I Until such time as POL issues further guidance on the
Juse of WhatsApp when communicating with
Postmasters the following protocols should be adopted:
2) The use of WhatsApp should be discouraged and
Icommunications with PM routed via a POL email
address.
12) Any decision to use WhatsApp when communicating
with PM to be authorised on a case by case bases by
Head of Contracts.
I3) Communication between Contracts and the PM via
IWhatsApp must be restricted to a POL mobile phone,
/4) Communications between Contracts and a PM via
lwhatsApp must be downloaded at the end of each
Iworking and saved to the case file,
Tile WahGp Toes prove a USOT eas
Jcommunication, when used in an investigative setting does
present security, data governance, disclosute and investigation
ranagoment challenges.
security - While WhatsApp does provide end toend encryption,
the phone containing the messages lost or stolen, and
particularly ithe phones not password protected, sensitive
POL data may be compromised,
ata Governance ithe event that POL receives 2 OSAR or FOL
request the DPA team may need to search mobile phones to
Jensure respondent dat is capture data,
Disclosure» There isan obligation in both civiland criminal
investigations to retain and record all elevant material this
Includes communications on WhatsApp. Failure to comply with
such obigations may expose Contract Advisors to a potential
charge of perverting the course of justice.
nvestgation Management - i imperative thatal members of
the wide ase tam have acess to allrelevant mateiin the
Jcaze when mating deceions relating tothe matter under
investigation,
[sending and rcoving electronic communications via @ POL
Jemait address would resolve many ofthe issues highlighted
Isvove and therefore the use of WhatsApp should be
ed.
Update (21/03/2024) - agree with the
recommendation, although a wider business use policy
needs to be considered. Happy to adopt the following:
3) Ihave discouraged the use of WhatsApp and that
Jemail comms be used as far as possible
2) The team will agree with me on its use.
3) Communication are already restricted to a POL
Imobile phone and personal phones are not used
4) A copy of any WhatsApp communications are kept
Jon the ‘contact log’ maintained by the team
Fe)
POL-BSFF-104-0000251_0022
POL00448292
POL00448292
Assurance & Complex Investigations
Head of Investigation Branch _ Senior Investigations Manager
John Bartlett Andy Morley
POL-BSFF-104-0000251_0023