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From: "Parsons, Andrew" <
To: "Prime, Amy" <
Subject: RE: Disclosure of Security Investigations Guidelines [BD-4A.FID26896945]
[UNSCANNED]
Date: Wed, 5 Oct 2016 10:55:47 +0000
Importance: Normal
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One addition below. Little tip — try to always spell out exactly what is required from the client (even if that is nothing or
a negative statement like below).
Andrew Parsons
Partner
Bond Dickinson LLP
www.bonddickinson.com
From: Prime, Amy
Sent: 05 October 2016 11:30
To: Parsons, Andrew
Subject: Disclosure of Security Investigations Guidelines [UNSCANNED]
Andy
Please find below a draft email to Rod on the Investigations Guideline - would appreciate your thoughts /
comments on this.
Thanks
[DRAFT]
Rodric
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The below is not urgent but for you to consider as and when you get a chance.
Freeths have requested that we provide them with Post Office's Investigations Guidelines since 1998 (including any
revisions to date). In the earlier round of disclosure we did not provide the guidelines since we wished to confirm
whether the documents were covered by privilege. Brian Altman has confirmed that they will not be covered by
privilege and as such the guidelines will, at some point, have to be disclosed.
We have reviewed both the most recent version of the guidelines (which were adopted in January 2016) and the
prior version (which were adopted in August 2013). Of note, the 2013 version (attached, password: Greeensky1)
provides "Should the recent Second Sight review be brought up by a subject or his representative during a PACE
interview the Security Manager should state: ‘I will listen to any personal concerns or issues that you may have
had with the Horizon system during the course of this interview".
Freeths will more than likely use this statement as an opportunity to confirm that Post Office responded to
postmasters using stock answers (an point which has already been raised in relation to the helpline) and further
could be spun to show that Post Office was not taking issues with Horizon seriously and were trying to ignore any
issues which were raised.
Although we may face some criticism later on, we are proposing to try and supress the guidelines for as long as
possible on the grounds that the most recent version is not relevant since it post-dates the investigations
complained of and it would require a full disclosure exercise to piece together all historic revisions of the
guidelines. We thought it would be best to bring this to your attention early.
If you would like to discuss the above please do not hesitate to call.
Kind regards
Amy
Amy Prime
Solicitor
Bond Dickinson LLP
Follow Bond Dickinson:
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www.bonddickinson.com
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