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Horizon Issues with Notes for Expert Meeting of 11/04/18
No. I Issue ‘GPOC (and Reply) citations Generic Defence citations Charteris Preparation Notes (not I Jason Coyne (JC) suggested examination
shared with the Claimants) plan/ensuing discussion on 11 April 2018
1 I To what extent was it possible or likely for 23. However, the Claimants aver ‘49. As to paragraph 22: GPOC 24.1 introduces error Attendees: James Hartley (JH); Imogen Randall (IR);
bugs, errors or defects of the nature alleged I that there were a large number of repellency. ‘Andy Parsons (AP); Jonny Gribben (JG); Robert
at §§ 23 and 24 of the GPOC and referred to I software coding errors, bugs or (1) If and to the extent that the Claimants Worden (RW) and Chris Emery (CE)
§§ 49 to 56 of the Generic Defence tohave I defects which required fixes to be wish to assert that any of the shortfalls I Should the experts agree a
the potential to (a) cause apparent or alleged I developed and implemented. There for which they were held responsible definition of the term? JC- we need to understand how bugs were recorded.
discrepancies or shortfalls relating to were also data or data packet were Horizon-generated shortfalls, itis In JC's experience, bugs are identified in two ways:-
Subpostmasters’ branch accounts or errors. There was a frequent need for them to make that distinct If so, should the definition apply * by testing; and
transactions, or (b) undermine the reliability I for Fujitsu to rebuild branch allegation and seek to prove it. Post specifically to the types of bug by users.
of Horizon accurately to process and to transaction data from backups, Office notes that they do not make the I identified in issue (1) - i.e. those
record transactions as alleged at §24.1 GPOC? ig rise to the further risk of allegation in the GPOC. It further notes which cause shortfalls or poor In both cases, we need to know where records of the
error being introduced into the that, in paragraph 20 of their solicitors’ I reliability? bugs are stored.
[GPOC §23 and 24; Defence §§49 to 56] branch transaction records. The letter to Post Office's solicitors dated
Claimants understand that Fujitsu 27 October 7016, the Claimants make it I Should the definition attempt to RW-we aren't looking at all types of bug, we need to
maintained a 'Known Error Log’ clear that they do not allege that there I clarify the classes of error described I focus on narrow set that could have caused
relating to some or all of these is a systematic flaw in Horizon or in 24.1? discrepancies. JC agreed.
issues which was provided to the indeed any flaw which has caused any
Defendant, but which has not been Claimant to be wrongly held Should we classify ‘shortfalls’ into: I JC-we can strip out bugs relating to anything that
disclosed. responsible for any shortfall. ‘© transient shortfalls, idn't go live, but if an issue has been recorded with
‘© permanent shortfalls? live running software (internally or externally) the
24. Further, the Claimants aver and I (2) Itis denied that Post Office has testing in respect of that software will be relevant.
rely upon the following: unreasonably or otherwise failed to (this is quite a big question whether
provide "obviously relevant disclosure" I to reveal our thinking here) RW-—even stripping that out, still a lot to look at.
24.1. Insufficient error repellency in in relation to bugs, errors or defects in Instinct would be to look at bugs from the start - is
the system (including sufficient Horizon. There has been no order or Should the experts agree the scope _I this a thing that could have impacted on branch
prevention, detection, application for disclosure and, in the _I of Horizon? accounts? Need to keep that focus.
identification and reporting of premises set out above, there appears
errors), both at the data entry level to be no basis for providing such Does JC consider that certain parts I CE —for example, I wasn't able to connect to the data
and at the data packet or system disclosure. of Horizon were particularly prone to I centre, fixed in half an hour. Not relevant. JC agreed
luding data processing, these errors, and if so which parts I ~is there a track for looking into issues (we do have
effecting and reconciling 50. Paragraph 23 is embarrassing for its lack I are they? Peak numbers — need to look at them)?
transactions, and recording the of particularity, in that (amongst other
same); things) it does not identify the errors, bugs Does JC think the answer to issue 1 JC - I'm interested in the Peak system, which comes
or defects on which the Claimants rely or depends on: after the helpdesk system (description from EDQ = "If
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24.1A bugs and/or errors and/or
defects in Horizon and any data or
data packet errors had the
potential to produce apparent
shortfalls which did not represent a
real loss to the Defendant;
24.2. Horizon is imperfect and has
the potential for creating errors (as
the Defendant has admitted in pre-
action correspondence, in the
Letter of Response, dated 28 July
2016, at paragraph 1.3);
24.3. bugs and/or errors have on
some occasions produced
discrepancies and/or apparent
shortfalls (as the Defendant has
admitted in pre-action
correspondence, in the Letter of
Response, Schedule 6) and such
shortfalls may also have arisen
from data or data packet errors;
and, further
24.4, the Defendant sought and/or
recovered such alleged shortfalls
from Subpostmasters (as is
presently understood to be
admitted by the Defendant in the
Letter of Response, Schedule 6,
paragraphs 4.1 to 4.5).
how “large” their number was or the period
in which they are said to have occurred and
nor does it identify the transaction data that
Fujitsu is alleged to have rebuilt, how
frequent" was the need to rebuild it or the
extent of the "risk of error" which is said to
have been introduced. In the premises, Post
Office cannot plead to the first three
sentences of this paragraph.
However:
(1) All IT systems experience software
coding errors or bugs which require
fixes to be developed and
implemented. As is noted in paragraphs
53 and 54 below, there are robust
‘measures in place in Horizon for their
detection, correction and remediation.
Q
All IT systems involving the
transmission of data over the Internet
experience data or data packet errors
during transmission and such systems
routinely have protective measures in
place to prevent such errors creating
any difference between the data
transmitted and the data received and
retained by the recipient. Horizon has
robust controls making it extremely
unlikely that transaction data input in a
branch would be corrupted when being
transferred to, and stored in, Post
Office's data centre in a
‘manner that would not be detected
and remedied,
(3
Like all IT systems, Horizon has backups
to guard against any loss of data due to
local hardware failure. Where hardware
fails, the data on that hardware is
recovered from the backup. Post Office
takes the term "rebuild" to refer to the
situation before the introduction of
software design and
code?
development practices?
tests and test results?
in-service history?
checks which would
reveal the presence of
such errors?
Fujitsu identifies an issue in Horizon or Horizon Online
that requires a programmatic fix then it is logged in its
database, the Peak System, and labelled as a 'Peak’.").
JC- there are several diagrams of the Horizon system
in the technical documents. To assist the Court, we
could produce a flowchart of the relevant ones.
AP - do you see bugs that impacted SPMRs but not any
of the claimants, in or out of scope? JC will produce
a table that has the bugs and a column which says yes,
no or potentially. JC ~ if we can say they are not
relevant to the 500 claimants.
AP - this is not a general enquiry into Horizon;
consideration must be given to relevance.
RW- we need to look at "shortfalls". The system.
contains lots of stuff to ensure that mistakes (e.g.
human error) are detected. Are we looking at
transient or permanent shortfalls? JC - not saying we
need to agree an outcome, trying to agree a method
for us to provide a joint opinion. RW ~ trying to think
about how filtering the "peaks " works. JC— with your
knowledge of the system, should be able to assist us
with keyword searches, glossary etc. to identify
relevant material.
JC- Ihave seen the KELs. and if the peak system is the
same, we should be able to make progress quickly.
JH - discussion(s) between experts needs to start
earlier than 22 June.
AP - you need to tell us what you are looking for. JC-
shortfall, error or whatever the code words. AP: that
still feels general - diff products, processes etc. ~
there is a logic in focusing search by reference to
issues. This is not a general enquiry.
JC: we don't need to be specific — we have been
ordered to look for issues.
AP - I expected to hear that you've spoken to 561
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Horizon Online where a new terminal
was introduced to a branch and the
data stored on the other branch
terminals (or on a disc where it was a
single counter branch) was restored to
the new terminal. In this context, Post
Office does not accept that there was a
“frequent” need to "rebuild" data from
back-ups.
(4) It is admitted that Fujitsu maintain a
"known Error Log”. This is not used by
Post Office and nor is it in Post Office's
control. To the best of Post Office's
information and belief, the Known
Error Log is a knowledge base
document used by Fujitsu which
explains how to deal with, or work
around, minor issues that can
sometimes arise in Horizon for which
(often because of their triviality)
system-wide fixes have not been
developed and implemented. It is not a
record of software coding errors or
bugs for which system-wide fixes have
been developed and implemented.
51. In paragraph 24, the Claimants again
bundle many ambiguous and/or misleading
allegations together. Post Office separates
out and addresses those allegations in
paragraphs 52 to 56 below.
52. As paragraph 24.1 does not explain what
is meant by "error repellency", what sorts of
errors are referred to, what is meant by
"data entry level", what would constitute
"sufficient" prevention, detection,
Claimants and present a set of common themes
arising out of that. It is unhelpful to start from a
premise that there are generic problems in Horizon
when there are 561 Claimants. Draw some themes.
JC- as experts, not been asked to do that.
JH.- you are suggesting that Claimants should identify
what has gone wrong and get experts to look at it; we
are saying that you need to look at it sequentially. In
any event you have 561 Schedules of Information. AP
- they don't cover this question.
JC—need to come up with terms to extract relevant
information from the databases.
JH — don't forget about the work done on the
mediation scheme.
RW- I am starting with a floodlight - itis for JC to
produce a spotlight on certain issues and for RW to
follow with his spotlight.
AP: looking for a two way street. What are you
looking for? JC - itis dangerous to filter too early; you
have to do collection first. AP: also needs Claimants
to set out themes. JH: there is a third strand — Post
Office needs to say what has gone wrong. AP -it is
not for us to run your case.
AP - what is your objection to asking 561 claimants
what they think the issues are? JH - we have spent
£1million speaking to claimants;. AP - not about the
theories of the causes of their losses. JC - by the time
you get to the peaks, won't be any commentary on
user experience. CE - original observation will be
relevant. JC: - more likely to see that "there was a
shortfall"
JC- TCs ~ Claimants would have no idea there was an
issue and ten they'd get a TC.
JC- Peak system seems to be the point in time that
someone has decided there is a bug (code needs to be
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identification or reporting of these errors, or
in what respects the error repellency of
Horizon was insufficient, Post Office cannot
plead to this paragraph. However, the
general thrust of paragraph 24.1 is denied
and the robust controls, procedures and
practices pleaded in paragraphs 53 and 54
below are noted.
53. As to paragraph 24.1A, it is a truism that
errors or bugs in an IT system and data or
data packet errors have the potential to
create errors in the data held in that system.
However, Horizon has at all material times
included technical control measures to
reduce to an extremely low level the risk of
an error in the transmission, replication and
storage of the transaction record data.
These have varied from time to time and
they currently include the following:
(1) Horizon creates, transmits and stores
n data in the form of
is a complete
transactional session between a
customer and Post Office and may
include one, several or many individual
transactions taking place within the
same session. Horizon will not accept a
basket of transactions that does not net
to zero (i.e. the value of any sales is set
off by the value of any payment made
or received). This reduces greatly the
risk of any error in the data entered
within any given basket.
Q
If a basket of transactions fails properly
to complete its transmission to the
central database (because, for example,
of a power loss), the system rejects any
partial transmission and requests the
full basket from the branch terminal
This reduces greatly the possibility of
baskets of transactions failing to be
changed).
JH - shall we discuss who at FJ and Post Office the
experts want access to. AP - concerned by the
suggestion that you want the experts to speak to
individuals, JH - the order provides for further
information to be provided and information can only
be provided by meeting the relevant people. AP
disagreed.
JC—I've given some thought to a process for
understanding the issues and devised some questions.
The numbering system is deliberate so that I can add
supplemental questions as thinking develops and
there are some gaps where I've decided questions
aren't relevant.
1.10 explain how internal bugs are recorded,
1.11 how does a SPMR report bugs?
1.21 need to understand help desk system
1.22 second and third line support
1.25 If a bug is determined, how is the impact of that.
considered (some bugs may be cosmetic)?
1.26 how is this factored into the development cycle?
1.27 probably a code versioning system, where we can
see the code changing
1.28 release management
1.29 release note
Peak system = very deep dives into code. JH - we have
Richard Roll saying to Panorama that Fujitsu employed
30 odd people on code; constantly firefighting (fine,
big system) pushing out code into system — therefore
coding may be an issue. RW — code may be relevant,
but Peak will require deep dives, to keep perspective
as to where you are is quite demanding.
RW ~cross-checks are important. If that bug had that
effect, would manifest here, here etc.
JH - how would that information be gathered? JC-
experts produce a statement, ask who the right
people to speak to are and then potentially experts
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2 Did the Horizon IT system itself alert
‘Subpostmasters of such bugs, errors or
defects as described in (1) above and if so
how?
[GPOC §23 and 24; Defence §§49 to 56)
3 I To what extent and in what respects is the
Horizon System “robust” and extremely
unlikely to be the cause of shortfalls in
recorded.
(3) At the point of a basket being accepted
by Horizon, it is assigned a unique
sequential number (a "JSN") that allows
it to be identified relative to the other
baskets transmitted by that branch.
This reduces greatly the risk of
recording duplicate baskets or there
being a missing basket.
(4) Each basket is also given a digital
signature, i.e. a unique code calculated
by using industry standard
cryptography. If the data in the basket
were to change after the digital
signature was generated, this would be
apparent upon checking the digital
signature.
(5) Initial data integrity checks are
undertaken when baskets are received
at the Post Office data centre from a
branch. Baskets are then copied from
the central database to the Audit Store
where a digital seal is then applied (the
“Audit Store Seal"). If the baskets
and/or the data within the baskets
were altered after the application of
the Audit Store Seal, this would be
apparent when the baskets are
extracted from the Audit Store.
Horizon and the above controls are
themselves subject to various audits
and checks including audits carried out
by third parties.
IG
54, Further as to paragraph 24.1A, in
addition to the technical controls referred to
above, there are several operational
procedures and practices conducted by Post
Office and Subpostmasters that serve to
increase the reliability of the data stored in
put the call in and go down to understand.
RW -need to look at the KEL first and we would both
have a better understanding of where we need to go.
JC- we have been told that the KEL doesn't have
everything (just what has/hasn't been resolved).
1.29.5 — need to know where the KEL ends and Peak
begins.
1.30 experts review system and attempt to agree if
the discrepancies and shortfalls have been considered
and impact assessed.
JC envisages Peak records saying something was likely
to lead to a shortfall or, as a programmer, looked at it
and won't lead to any shortfalls. RW — looking at
peak, expect to see list of acronyms.
1.50 — the Defence para. 50(2) talks about robustness.
RW ~ robustness is elsewhere.
‘What kinds of alerts are envisaged
here?
2.10 = did the SPMIR get reports of bugs via Horizon
(if release notes are given to SPMRs)?
JG - Ask the Claimants; JC agreed.
JH sees it as an extension of the demo. Guidance and
insight from someone that understands the system
(e.g. Dave). AP - Dave unlikely to know about that.
JC - we know that there were two specific bugs (local
suspense and receipts and payments mismatch) —
could take those as specific examples.
2.20 ~ Post Office ISO driven — is there a defined
process for this?
‘AP - does this extend beyond the scope? JC agreed.
Should the experts agree a
definition of 'robust'?
3.10 what is a “shortfall” (JH — also "discrepancy") (AP
— may make sense to produce an agreed terms
dictionary - agreed).
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branches? the central data centre as an accurate For shortfalls, see against issue (1)
record of the transactions entered on above 3.20 - once we have agreed what a shortfall is, need
[GPOC §23 and 24; Defence §§49 to 56] branch terminals. These currently include to map out what the possible causes of it are. E.g.
the following: user error (miskey) ~ not a systematic shortfall. RW —
list? Bad reference data? Could come up with useful
(1) For many transaction types, Post Office headings. Logically need to compartmentalise, start
compares its own transaction record to create boxes to put individual claims in.
against the corresponding records held
by Post Office clients. If an error in 3.30 — review design documents ~ mechanism to
Horizon were to result in the corruption detect shortfalls. Every accounting system has a trial
of transaction data, this should be balance. RW ~ loads of checks and balances,
revealed by the comparison. cataloguing them is non-trivial. JC— doesn't need
anything in addition to the technical documents he is
(2) There are detailed procedures in place going to be getting for this.
to address the risk of data loss resulting
from interrupted sessions, power 3.40 review protective measures, procedures and
outages or telecommunications failures controls to prevent data or data packet errors during
in branches. These are set out in the transmission. JC-don't need any further info.
"Recovery —Horizon Online Quick
Reference Guide" and Horizon guides 3.50 Charles McLaughlin report mentions SPMR's
the system user through the recovery previously used to receive a discrepancy report;
process (which include completing any these are no longer available. How was the
transactions that are cut short). These discrepancy report was made up, why replaced and
procedures should prevent any data by what mechanism?
errors arising from interrupted
sessions, power outages and
telecommunications failures.
(3). The display of the transactions being
effected on-screen at the branch
terminal allows the user of the system
to identify any inconsistency between
the information shown on the screen
and the transaction that the user has
keyed into the system. If, for example,
a hypothetical bug in the terminal were
to cause a key-strike on number 5 to be
recorded as an input of number 6, this
would be detected rapidly by system
users, given the large number of system
users and the huge number of
transactions effected on Horizon,
(4) The accounting and record-keeping
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obligations placed on Subpostmasters
reduce the risk of any errors going
undetected. For example, there is an
obligation for each branch to count and
declare to Post Office the cash it holds
on a daily basis, which increases the
likelihood of promptly detecting any
overstatement or understatement of
the cash position on Horizon. If a
Subpostmaster detects that an error
has been made at an early stage, its
cause is more likely to be identified.
5
Fujitsu operates industry standard
processes for developing and updating
Horizon and for investigating and
resolving any identified potential
system errors.
55. As to paragraph 24.2, Post Office admits
that, like all other IT systems, Horizon is not
a perfect system which has never had any
errors or bugs. However, as indicated in
paragraphs 53 and 54 above, it has robust
systems in place to identify them, fix them
and correct their consequences (if any).
56. As to paragraphs 24.3 and 24.4:
(1) There have been occasions on which
bugs or errors in Horizon have resulted
in discrepancies and thus shortfalls or
net gains in some branch accounts, as
outlined in Schedule 6 of the Letter of
Response. It is denied (if it be alleged)
that such bugs or errors have affected
any of the Claimants.
(2
On each occasion, both the bugs or
errors and the resulting discrepanci
in the relevant branch accounts were
corrected. Post Office took steps to
ensure that it had identified all
branches affected by the bugs or errors
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and that no Subpostmaster was
ultimately held responsible for any
resultant shortfalls.
@
Paragraphs 4.1 to 4.5 of Schedule 6 to
the Letter of Response relate to the so-
called Suspense Account Bug. Without
prejudice to the burden of proof, none
of the branches affected by the
Suspense Account Bug are branches for
which the Claimants were responsible.
(4)
None of the Subpostmasters whose
branches were affected by the
Suspense Account Bug were ultimately
held responsible for the shortfalls that
it generated. The Claimants are
therefore wrong to understand Post
Office as having admitted that it
“recovered such alleged shortfalls from
Subpostmasters". Where
Subpostmasters in the affected
branches had made good or settled
centrally shortfalls that were later
corrected, those Subpostmasters
received a payment or credit in the
amount of the shortfall.
4 _I 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?
[GPOC §§5, 14-15, 24.1, 24.1A, 94A, 95;
Defence §§35(2), 36, 38(1), 50(1), 52-54;
Reply §41
5 I How, ifatall, does the Horizon system itself
compare transaction data recorded by
Horizon against transaction data from sources
le of Horizon
5. In each branch itis the
Defendant which determines the
products and services which must.
be made available. Over time, the
Defendant has increased the
number and complexity of the
products and services which it has
required to be provided through its
branch network.
14. As particularised further below,
the introduction and imposition of
Horizon in 1999/2000:
14.1. significantly changed how
Claimants were required and able
3
As to paragraph 14;
(2) Post Office cannot meaningfully plead
to paragraph 14.1A since neither the
errors, nor the data entry, nor the
“sufficient error repellency" alleged are
identified. However, itis denied (if it be
alleged) that Horizon had poor checks
and controls for data errors.
36, Paragraph 15 is embarrassing for lack of
particularity. In the absence of any
indication as to the actual changes the
Claimants intend to rely on and as to the
effects) each such change is alleged to have
had, Post Office cannot plead to this
Does issue 4(a) data entry include
manual errors?
JC= need to look at design documents/technical
control documents. Defence para. 16. JC-has the
"Horizon is not perfect” , need to see when the
controls are triggered (links back to previous issue).
"Error repellencey" = protections against user error.
5.10 identify what sources are outside of Horizon;
CE—quite a long list. AP — do you mean data that has
fed back in? JC—yes.
‘AP: where do you draw your line? JC— there is a
batching layer ~ all transa
ns (e.g. national rail) get
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[GPOC §§5, 14-15, 24.1, 24.1A, 94A, 95;
Defence §§35(2), 36, 38(1), 50(1), 52-54;
Reply §41
6_I To what extent did measures and/or controls
to work in their branches from the
position previously and, in
Particular, the position which
prevailed at the date the terms of
the 1994 SPMC were introduced;
14.1 A introduced the potential for
errors to be made during data entry
and/or failed to introduce any or
sufficient error repellency (as at
paragraph 24.1 below);
14.2. limited Claimants’ ability to
access, identify, obtain and
reconcile transaction records; and
14.3. limited Claimants’ ability to
ste apparent shortfalls,
particularly as to the underlying
cause thereof.
15, Further or alternatively,
subsequent changes to it and/or
changes to products and services
which the Defendant required to be
offered had the aforesaid effects on
the Claimants.
24.1. Insufficient error repellency in
the system, including sufficient
prevention, detection,
identification and reporting of
errors}, both at the data entry level
and at the data packet or system
level (including data processing,
effecting and reconciling
transactions, and recording the
same);
24.1 bugs and/or errors and/or
defects in Horizon and any data or
data packet errors had the
potential to produce apparent
shortfalls which did not represent a
paragraph. However, Post Office notes that,
on the Claimants' pleaded case, any
changes in the Claimants’ ability to access
records and investigate shortfalls caused by
the introduction of Horizon or by
subsequent changes to Horizon or to
products and services offered has no
apparent relevance to any of the breaches
of contract or other claims advanced in the
GPOC. As regards such changes, paragraph
35 above is repeated, mutatis mutandis.
38. As to paragraph 17:
(1) Save for the "others" referred to,
whom the Claimants do not identify,
the first sentence is admitted. The
processes for transferring transaction
data from branch to Post Office's
central data centre, and the controls.
ensuring the accuracy of that data
transfer, are discussed in paragraphs 53
and 54 below.
50(1) See above.
52-54 See above
put together. CE — there are common gateways. RW
= expects that in every case where POL has a business
relationship with a claimant, there will be some
reconciliation.
CE — does Horizon itself (APS, DRS ~ the parts of
Horizon that have reconciliation).
‘AP —do you mean messages on a transaction by
transaction basis or periodic accounting?
JH - can we agree in principal that the experts will be
working in parallel! - same amount of information,
AP - absolute parity v. difficult. AP—needs a
mechanism for obtaining parity. JH ~ could have a
document listing what docs the experts have
requested/accessed. JH ~ significant things e.g.
meeting with FJ/PO person for a day, Freeths would
say they should have access. AP: this will cut both
ways - we would want access to Claimants.
5.20 reconciliation (e.g. DRS).
5.12 batching service says it sends and receives info
from XXX.
5.13 - key to answering question about how it
compares = how does it agree with differences? RW
= huge question. Will be discrepancies being
detected all over the place. JC ~ does that difference
end up on the branch account?
‘AP ~ the reconciliation (human bit) is outside of the
scope of Horizon (gap is out of scope ~all agreed). JH
— judge trying to keep it narrow, no factual evidence.
JH ~ judge needs to understand what happens in that
space, markers need to be put down.
5.13 -a need to look at ATM declarations. (branch
operating book describes that process)
JC~ lots of other things will come out
Issue 6 asks to what extent
6A — data entry errors
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that existed in Horizon prevent, detect,
identify, report or reduce to an extremely low
level the risk of the following:
a. data entry errors;
b. data packet or system level errors
(including data processing, effecting, and
recording the same);
c. a failure to detect, correct and remedy
software coding errors or bugs;
d. errors in the transmission, replication
and storage of transaction record data;
and
e. the data stored in the central data centre
not being an accurate record of
transactions entered on branch terminals
[GPOC §§5, 14-15, 24.1, 24.1, 94A, 95;
Defence §§35(2), 36, 38(1), 50(1), 52-54;
Reply §41
real loss to the Defendant;
94A. The Defendant failed to
provide a system which was
reasonably fit for purpose,
including and or adequate error
repellency (as at paragraph 24.1
above).
95. By reason of bugs and/or errors
or otherwise, the Defendant failed
properly to execute and reconcile
all transactions which the Claimants
initiated or effected and/or to
record and maintain accurate
transactional records in relation to
such transactions.
Reply 41. As to the allegedly robust
controls pleaded variously at
paragraphs 16, 50 and 52 to 54 of
the Defence:
41.1. the Defendant's case that “its
design and technical controls, when
supplemented by the various
accounting and cash controls
applied in branches, make it very
unlikely indeed that an error in
Horizon could affect a
Subpostmaster's financial position
‘and go undetected" (Defence
paragraph 16, emphasis added),
implicitly accepts that Horizon is
likely to be the cause of
discrepancies or apparent or
alleged shortfalls in branches,
unless detected by Claimants;
41.2. the Defendant has failed to
plead to any material variations in
the operation of Horizon and its
control measures over the period of
the Claimants' claims, and has
measures and controls in Horizon
prevented certain errors, of
categories (a) -(e).
For each of the categories (a) -(e),
isit to be understood that the
‘errors' include only those errors
identified under issue (1) - Le.
errors which cause shortfalls or
apparent shortfalls?
Reply 41.2 addresses the possible
variability of the level of controls in
Horizon over the period of the
claim,
Has JC identified particular periods
he intends to focus on?
Does JC endorse the argument put
6.10 - need to look at design documents to see if the
design considered these things.
6.12 - we have specific reports of accounts being
mis-keyed and then cancelled which might need to
shortfalls, need to look at this as a specific example.
Might help us to understand iterative design process.
6.20 ~ search of data entry error entries in helpdesk,
give a view as to whether there is a problem. How
many data entry errors do you expect? AP — the
scale of the exercise; not sure records are keyword
searchable. JC bet that one of the codes (A04) is a
miskey error). AP - sampling?
RW - there will be guides re user interface that deal
with data entry errors. Helpdesk search would have
to be ona sample basis.
AP - input from the Claimants would be useful.
JC-how to guides get bigger as mistakes are spotted.
JH ~ management info in Post Office. JC - not sure of
relationship between PO and FJ ~ mechanism for Fd
suggesting improvements. JH - meetings between
Federation and Post Office (website re report branch)
— query what was done with all of that. CE —out of
scope? JH need Post Office to help us ID
documents re errors. JC~ specific measures and
controls in the system — design comes from Post
Office's desires, presumably they are introducing new
measures and controls. Understanding the interface.
RW ~are we concerned with process of improving H?
JC—we can look at today’s version, in 2009 what
controls and measures were in place. Source = what
the parties were talking about. If there is a different
way of doing it, happy to understand it. RW —
presumably user guidance material over time. CE ~
documentation re actual controls built in. JC—
process of what got in out of scope, changes in scope.
CE ~ must be formal procedure for controls. RW ~
development team of several 100s over several
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refused the Claimants RFI in this
respect,
pleading only to the current
operation of Horizon (and
responding to the RFI only that ‘in
general terms, the basis processes
‘and practices set out in paragraph
54 of the Generic Defence have
been in place since the introduction
of Horizon’);
41.3. as to the Defendants’ pleaded
current position, the Defendant is
in any event put to strict proof of:
(a) the ‘robust measures in place
in Horizon’ for the ‘detection,
correction and remediation’ of
software coding errors or bugs
(paragraph 50(1)), what these
measures are, when they were
introduced and their efficacy;
and
(b
the pleading that "Horizon has
robust controls” in respect of
data packet and other data
transfer and storage errors
(paragraph 50(2)), what these
controls are, when they were
introduced and their efficacy;
(0
the pleaded "robust controls,
procedures and practices"
(paragraph 52), what these
controls are, when they were
introduced, and their efficacy;
(d)
the pleading That "Horizon has
at all material times included
technical control measures to
reduce to an extremely low
level the risk of an error in the
transmission, replication and
forward in Reply 41.2?
Reply 41.3 puts PO to strict proof
on aspects of the robustness of
Horizon, in various respects.
Has JC identified any of the respects
(a) -(d) in which he thinks that
proof cannot be provided?
Reply 41.5 appears to raise factual
issues about the KEL, rather than
expert issues.
How does JC intend to investigate
the KEL?
years. Need to do prelim survey first and get that
right... JC - proper change management system in
place.
JH ~ concerned we are not nailing anything down.
6B data packet or system level errors
RW funny conjunction. JC - understand that there
is system level logging (net call logs) (FJ at the model
office - record hardware and communication at the
windows NT box) ~ what did H do with these logs? FJ
talked about communication, monitoring the
condition of disk platters.
6.20 — how did Horizon deal with system logging
(asking for information)?
RW Q6 as a whole ~ is the scope any old error or
errors which lead to shortfalls. JC errors that have
the potential to lead to shortfalls.
JC- by speaking to someone, can understand this.
JH — in pleading this, presumably talked to someone
in PO/FJ?_ AP ~ not prepared to discuss production of
pleading ~ privileged. JH ~is POL going to help
experts where the information is stored. AP — part of
a larger question. You clearly want information via
emai
RW starting from a different position — floodlight,
waiting for you to put the spotlight on it.
‘AP - are you asking if there is a person that could
answer it? Hope so, don't know who. And how we
deliver that information to you.
RW — meeting could be about sources of information,
not delivery of information. Meetings = pointers on
documents, not information.
JC~if we had an hour with X (head of helpdesk at an
operational level), they will see there are X
documents. CE - if we ask where the document s are
ina meeting.
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storage of the transaction
record data" (paragraph 52},
when each of the measures
pleaded at subparagraphs (1}
to (6) was introduced, what if
any measures they replaced
and, in each case, their
efficacy;
41.4. further, in respect of the
alleged ‘robust measures in place in
Horizon’ for the ‘detection,
correction and remediation’ of
software coding errors or bugs
(paragraph 50(1)), the Claimant
denies that these were effective,
including on the basis that two of
three errors or bugs admitted by
the Defendant (in Schedule 6 to the
Letter of Response, referred to at
paragraph 56 of the Defence) were
not identified through Horizon's
‘own in-built checks and balances
designed to identify the same (as to
which the Defendant has refused to
answer the Claimants RFI -
Responses 34 to 36);
415. in respect of the Known Error
Log (Defence, paragraph 50(4)):
(a) itis denied that the Known
Error Log is not in the
Defendant's control;
(b) the Claimants note Defendant's
refusal to admit whether data
derived from the Known Error
control, and refusal to identify
whether the Defendant is
contractually entitled to the
Known Error Log or any report
or data derived from it
Reply 41.7 on recovery procedures:
does JC endorse this para? Has he
seen evidence that recovery
procedures were unclear or
ineffective?
Reply 41.8: How does JC understand
the term ‘screen calibration error’?
Reply 41.9 balances changing
overnight: can the experts address
this question without considering
factual evidence about individual
claimants, which is out of scope for
the Horizon trial?
JH to provide his list of points. Documents
information and inspection. RW uncertain about
right ordering of the process of these documents,
information and inspection requests.
RW — meeting not the best way to kick off, might be
part of the process.
JC ~ matrix — his issues (methods of investigation)
6.20 understand the system level log in and how
Horizon dealt with these
6.21 [..]
RW -— numbering system has gone awry. JC to revisit.
6C ~ software coding problems.
6D and E - difficult to separate.
6.40 data seals. JC - something to do with
transmission?
RW private/public key inscription ; seals
JC - specifically looking at measures and controls.
JH = working back from deadlines in the order, if
experts have an agreed timetable it will be useful for
legal teams /how it will play out .
Replication = OK with it,
6.42 — audit reports and checks carried out by third
parties. Need to have a look at those.
6.44 — JSN checks. Not clear if they are executed
when we have a discrepancy. JC- if there is a
dispute about discrepancy/shortfall, are the experts
able to. CE -you're asking if any failed checks are
logged and if so where are they.
JC— baskets, still don't understand, cash is handed
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(Responses 26 and 27 to the over, if you then have a basket error and the
RFI; transaction doesn't go to Horizon because... (RW is
this recoverable transactions).
(c)_ the Defendant is put to strict
proof of the matters asserted Status of JSN checks ~ do they correlate with
at Defence paragraph 50(4) ‘to discrepancies? RW —vinteresting Q. JC— if there is a
the best of Post Office's report of a shortfall and a failed JSN check... What
knowledge and belief’ (as to does H do with them? RW~next reconciliation, it
which the Defendant has also comes out in the wash.
refused to answer the
Claimant's RFI); and 6.44 when does that check happen?
(d) the Claimants will provide
voluntary particulars on this
issue after full access to the
Known Error Log has been
facilitated and analysed by the
Claimants' experts.
41.6. paragraph 54(1) is wholly
ambiguous as to which transaction
types upon which the Defendant
carried out such a comparison, the
process and timeliness thereof, and
its efficacy (including the
statement, 'if'an error in Horizon
were to result in the corruption of
transaction data, this should be
revealed by the comparison’);
41.7. itis denied that the recovery
procedures which the Defendant
pleads ‘should prevent any data
errors arising’ (Defence paragraph
54(2)) were sufficiently clear or
effective to prevent such errors, or
indeed did prevent them, and it is
averred that the processes in place
were in fact ambiguous and/or
otherwise difficult to follow or
execute;
41.8. the Defendants' pleading as to
key strike errors (Defence
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Paragraph 54(3)) wrongly proceeds
‘on the basis that such problems
would be the result of a system
wide bug rather than a screen
calibration error;
41.9. paragraph 54(4) is denied in
so far as it is intended to amount to
a defence and in any event, breaks
down for Claimants where balances
change overnight without any
transactions by the Claimants,
which often occurred;
41.10. the Defendant is put to strict
proof of the alleged wholly
unparticularised ‘industry standard
processes for developing and
updating Horizon and for
investigating and resolving any
identified potential system errors’,
what those potential system errors
were, and what and when a
resolution was introduced.
7 I Were Post Office and/or Fujitsu able to access
transaction data recorded by Horizon
remotely (i.e. not from within a branch) TO
MODIFY DATA?
[Defence §7; Reply §9]
Reply 9. At paragraph 7, the
Defence materially understates the
Defendant's knowledge of what
happens in branches (in so far as
material to this case) and
overstates the knowledge of
Claimants. in that respect,
paragraph 7 is denied. (The
Claimants plead below, at section
‘A2, in respect of the information
available to Claimants after the
introduction of Horizon.) As to the
knowledge and access of the
Defendant:
9.1. the Defendant and/or Fujitsu
had access to all transaction data,
7. Subpostmasters run Post Office branches
on behalf of Post Office. They have day-to-
day operational control over those
branches and they and/or their Assistants
have direct knowledge of what happens in
them, By contrast, Post Office's knowledge
is largely based on the accounts, cash
declarations and other information from
Subpostmasters.
Issue 7 has a syntactic ambiguity. We
assume ‘remotely’ refers to ‘access’,
not to ‘recorded’,
If so, it seems the answer is trivially
yes.
7.10 Fi accept that they did on at least one occasion.
We need to understand what was the need for that
remote access. AP — lack of clarity re access (some
mean reading data, some mean writing data). JC -
Only interested in modifying data. JH —still need to
deal with both meanings.
AP — 10 deals with modifying.
7.20 ~is the transaction flagged in a particular way?
Look at the record of FJ amending to understand what
the impact on transaction was. AP — why is it
relevant? JC- if they inserted it because there was a
missing record, H has lost a record. Will help us to
understand. Will be an indicator — JC second question
is how many BTs have there been (will use data from
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8 I What transaction data and reporting
functions were available through Horizon to
Post Office for identifying the occurrence of
alleged shortfalls and the causes of alleged
shortfalls in branches, including whether they
were caused by bugs, errors and/or defects in
the Horizon system?
[Defence §7; Reply §9]
including a detailed stream of
transaction data (XML data) and all
transactions affecting the accounts
of individual branches, including
transactions linked to individual
users, system generated
transactions, and those initiated by
the Defendant and/or Fujitsu;
9.2, the Defendant admits that
from the introduction of Horizon
Online in 2010, transactions were
effected through real time
‘exchanges of data from branches to
central Post Office data centre
(Defence, paragraph 33);
9.3. the Defendant and/or Fujitsu
had access to overnight cash
holding (‘NCH’) data (further
pleaded at paragraph 22.4 below);
9.4, the Defendant and/or Fujitsu
had access to the Known Error Log
and/or other similar logs or records
of system bugs and errors;
9.5. for the avoidance of doubt, all
such data and/or reports as were
available to the Claimants on
Horizon, as the Defendant contends
at paragraphs 38(2) and (3), were in
any event also available to the
Defendant;
9.6. the Claimants infer, and will
invite the court to infer, that the
Defendant was able to access data
and use reporting functions, which
were not available to the
Claimants:
PARTICULARS OF MATTERS RELIED
UPON
record to frame search).
AP — do you want disclosure of that transaction
record? JC yes.
7.30...
7.40 need to understand architecture of back end
database and understand who at FJ has access. When
FJ made this change to database, they inserted a BT.
JC—we know they were able to do this through a BT,
possible that any database administrator could do that
through uncontrolled access. CE — that would be no
logging access.
7.50 - there was reports of transaction reversals.
These use system/user ID. Went through with SPMR's
user ID. How was that done? AP— is that part of a
bigger question - can someone at F) pretend to be a
SPMR?
RW -worth drilling down on these and forming a view
as to what they involve.
In Issue 8, the use of the word
‘alleged’ seems inappropriate, since
the process of ‘identifying the
occurrence’ typically took place
before litigation or allegations.
Should ‘alleged’ be replaced by
‘apparent’?
The answer to issue 8 would appear
to be an extensive list, including for
instance audit, data warehouse, etc.
Should it be regarded as a factual
issue rather than an expert issue?
Do the claimants intend to catalogue
the list exhaustively?
RW~ reading it as apparent shortfalls.
JC= root is whether Post Office had reports available
to ID...
8.10 ~is there a shortfall report?
8.11 - on that report, does it set out the causes?
JH — definitions — can have experts, lawyers or a
combination? JC—simplistically, a shortfall leads to a
TC... JH = potential for confusion. Nervous about
definitions involving Horizon data.
JH — clause 12.2 talks about a "loss" — potentially
important distinction between shortfall/loss. JC — if
we can set them out in an agreed document, we can
refer to a key in a document.
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list of 4 or 5 scenarios
(a)
the Defendant admits that it JH and AP to come up
and/or Fujitsu could investigate
apparent shortfalls: paragraphs RW - concern — answer = lists of pieces of data and
46(4) and 54(5); functions; verges on factual list (to what extent is
expert commentary required). JC when we
the Defendant contends that investigate specific scenarios with claimants ~ was the
‘more extensive transaction report run and who was it run by.
data was provided, and further
data was provided outside [the JC- can we obtain a list of shortfall reports?
42 or 60 day] periods, where
this was necessary’: paragraph 8.20 - when discrepancies are discovered, is part of
136(2); the review process to consider if a bug, error. AP —
out of scope. JC—if out of scope, scenario is that you
the Defendant admits that identify a shortfall, there is a report saying a shortfall
‘Fujitsu provided a telephone but can't see what Post Office did with it. Abstract.
advice service to Post Office in
relation to technical problems CE~lead cases. JH — relevant factual context.
with the Horizon system or
equipment: paragraph 48(8);
(b)
(c)
(d)_ the Defendant contends that it
had a process for the
escalation of disputes including
a 'team responsible for
investigating branch matters’
which ‘undertakes a further
investigation into the disputed
amount, seeks to identify the
reason for it arising and
communicates with the
Subpostmaster concerned:
paragraph 46(4)(b);
the Defendant had the
discretion and contractual right
to request further data and/or
reports from Fujitsu (limited to
a specific number of requests
and/or at some cost to the
Defendant), both as to the
working of the system
generally, including bugs,
errors and fixes therein, and as
(e)
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to particular transactions or
branch accounts —further
voluntary particulars of which
will be provided once the
Claimants have been afforded
access to the Horizon system
and unredacted versions of the
contract with Fujitsu; and the
Defendant contends that ‘For
‘many transaction types’, the
Defendant is able to compare
its own transaction record
against the corresponding
record held by its clients:
paragraph 54(1).
9. I Atall material times, what transaction data
and repor
through Horizon to Subpostmasters for:
Issue 9 also has the flavour of a 9A
factual issue rather than an expert
issue. Its answer is a list rather than I Branch operating manual.
an opinion.
14. As particularised further below, I 38. As to paragraph 17:
‘ing functions (if any) were available I the introduction and imposition of
Horizon in 1999/2000:
(1) Regarding the second sentence:
Technical docs.
a) identifying apparent or alleged
discrepancies and shortfalls and/or the
causes of the same; and
14.2. limited Claimants’ ability to
access, identify, obtain and
reconcile transaction records; and
(b) While such transaction data is available,
Subpostmasters can search for, identify,
organise and analyse data by means of a
The parties might prepare factual
evidence, and the experts are then
Also covered by the demo.
b)
accessing and identifying transactions
recorded on Horizon? 14.3. ited Claimants’ ability to
investigate apparent shortfalls,
particularly as to the underlying
cause thereof.
wide range of reports, including a asked to endorse that itis accurate
transaction log report which identifies each _ I and answers the question.
and every transaction undertaken in the
relevant branch in the entire period. This,
report can be
focused in a variety of ways if desired,
including by reference to date ranges,
transaction types, stock items, value ranges
and even particular users or terminals.
9.05 review Branch Operating Manual to determine.
[GPOC §§14.2-14.3, 17 and 19.3; Defence
§§38(2)(b), 38(3), 46(2); Reply §15.2-15.3]
Scenario 10 - what receipts are printed (reporting
function) ~ two different receipts (one of customer
‘one for SPMR).
17. Horizon operated such that
transactions entered by Claimants
or others onto terminals in
branches were transmitted to the
Defendant's central data centre (2) He n provides Subpostmasters with
where they were processed, tools for searching, checking and
recorded, reconciled and retained. reviewing the transactions undertaken
Claimants were subsequently able in the branches for which they were
to access transaction data, as responsible.
recorded on the system, for a
limited period (42, and after the
introduction of Horizon Online, 60
days) and in limited report form by I (2) Itis denied that Subpostmasters are
requesting reports to be generated unable to carry out effective
by Horizon. These reports were investigations into the disputed
generated from transaction records amounts. So is the allegation that there
9.10 ~ customer
9.11 SPMR
If the figures are different? SPMR's doesn't have the
value on it. May be. Reporting function — later told
that the report was £100 but you gave them £1,000.
Reply 15, particularly (f) and (g), JC might be right, only SPMR receipt is of relevance.
seem to hinge on factual evidence
about individual claimants which is_I CE ~a factual question.
out of scope for the Horizon trial.
46. As to paragraph 19.3:
JC-is the individual amount retained on the slip? fit
is, will help them, if it isn’t, they might struggle.
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held by the central data centre,
19. The importance of the accuracy
‘of Horizon was accentuated by the
following.
19.3. Disputing ‘shortfalls’:
Claimants seeking to dispute
apparent shortfalls did not have an
option within Horizon to do so, and
were required to contact the
Helpline to seek assistance (see
paragraph 29 below). Claimants
who contacted the Helpline were in
any event required to settle any
disputed amounts centrally, albeit
collection was in some cases
suspended, apparently pending an
investigation by the Defendant.
Claimants were themselves unable
to carry out effective investigations
into disputed amounts because of
the limitations on their ability to
access, identify and reconcile
transactions recorded on Horizon
and the lack of any or adequate
report-writing features
in Horizon (as repeatedly raised by
Mr Bates). There were no
provisions, nor was there any or
sufficient guidance in the
Operations Manual as to the
procedure or process for disputing
discrepancies or apparent or
alleged shortfalls. The Defendant
failed to carry out any, or any fair
or adequate investigations into
disputed amounts.
Reply 15. Further, as to Claimants’
‘access to transaction data and
reports:
15.2. as to the ‘extensive range of
were unspecified “limitations” on
Subpostmasters' ability to access,
identify and reconcile transactions in
Horizon and that Horizon had no
“adequate report-writing feature”. As
indicated in paragraph 38(2) above,
Horizon provides Subpostmasters with
tools for searching, checking and
reviewing the transactions undertaken
in the branches for which they are
responsible.
9B
9.20 were error logs sent to SPMRs/were they visible
in branch?
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other reports’, the 'wide range of
reports’ and ‘tools for searching and
reviewing’ averted, at paragraphs
35(3), 38(2)(b) and 38(3):
(a). the ‘transaction log report’ was
in fact a print out on narrow till
paper, such that even a week's
worth of transactions would
produce 20 to 30 feet of paper;
(b)
like the ‘Balancing Snapshot’,
the ‘transaction log report only
showed one side of fine
transaction, so that the cause
of alleged shortfalls could
(usually) not be identified;
the Defendant has failed to
particularise what the available
reports and tools were and has.
refused to provide the
information sought in the
Claimants! RFI relating to these
Paragraphs — no admissions
are made that there are any
such reports (or any that would
materially assist Claimants in
identifying the true cause or
details of any alleged shortfall);
(c)
(a)
the Claimants note the
Defendant's admission at
paragraph 38(2)(b), that
whatever reports were
available, were only available
to Claimants via Horizon during
the 42 or 60 day period above;
(e)
after the 42 or 60 day period
above, Claimants had no access
to transaction data, tools or
reports (subject to paragraph
16 below) as the Defendant
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implicitly admits at Defence
paragraphs 38(2)(b) and
136(2);
(f
when alleged shortfalls were
raised, by way of Transaction
Corrections or otherwise,
outside the 42 or 60 day period
above, requests for provision
of the information which
would have been available to
the Claimants during that
period were often refused;
when a Claimant was
suspended, Claimants had no
access to the same (subject to
paragraph 16 below} and had
no access to personal records
held at their branch, as the
Defendant also admits at
paragraph 136(3);
(e
15,3. the Defendant is put to strict
proof of the practical utility of the
‘line by line’ data and/or any
transaction data or reports
available or provided to the
Claimants, for the purpose of the
Claimants trying to investigate
discrepancies or apparent or
alleged shortfalls — as to which the
Claimants contend that what they
had was of limited utility and did
not enable the Claimants to carry
out their own effective
investigations;
10
‘Whether the Defendant and/or Fujitsu have
had the ability/facility to: (i) insert, inject, edit
or delete transaction data or data in branch
accounts; (ii) implement fixes in Horizon that
had the potential to affect transaction data or
data in branch accounts; or (iii) rebuild branch
transaction data:
21, Pending full disclosure, the
Claimants understand that Fujitsu's
role included:
21.3. managing coding errors, bugs,
and fixes so as to prevent, manage
or seek to correct apparent
48. As to paragraph 21:
(3) Paragraph 21.3 bundles together
several different concepts and uses
language that is open to different
meanings and/or misleading. However:
The answer to issue 10I
be trivially yes. It was obviously
necessary for Fujitsu from time to
time to implement fixes, and this
could not have required the
knowledge or consent of
subpostmasters.
Change control process (see above). JC were they
following process?
(ii) - Richard Roll — Post Office having to reverse
engineer/rebuild. AP - Are you going to call him as a
witness? JH — haven't decided yet. Depends where
JC gets to. JH - on witnesses, do you have in mind
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a. atall; discrepancies in the data (including {a)_ Fujitsu's role included identifying calling witnesses? AP — can’t work out what Judge
b. without the knowledge of the between the said and remedying coding errors and I The answer to 10(i) is less trivial but I meant by "barest of factual evidence". JH ~ should
Subpostmaster in question; and systems), ina manner which would bugs in Horizon. would seem to require an make decisions by linking in to the factual matrix.
c. without the consent of the potentially affect the reliability of assessment of the controls on that I Our thinking is the Judge didn't have a view — all he
Subpostmaster in question. accounting balances, statements or (b) To the extent that the phrase if and when it existed. was bothered about is focus being on expert
other reports produced by Horizon; “correct apparent discrepancies in evidence. Riskis it escalates. All sorts of factual
[GPOC §§21.3, 23, 25; Defence §548(3), 50, I and the data” is intended to mean that witnesses in POL that we would love to examine.
57] Fujitsu implemented fixes that
23. However, the Claimants aver edited or deleted specific items of
11 I If Fi did, did the Horizon system have any that there were a large number of transaction data, that is denied. RW -— understand 11 to apply to 10(i), not (i) or (it)
permission controls upon the use of the software coding errors, bugs or We can talk about it in all three categories, but
above facility, and did the system maintain a I defects which required fixes to be (c) tis denied that Fujitsu has different.
log of such actions and such permission developed and implemented. There implemented fixes that have
controls? were also data or data packet affected the reliability of JC ~is there a log of such actions and how did the
errors. There was a frequent need accounting balances, statements or permission control work?
[GPOC §§21.3, 23, 25; Defence §§48(3), 50, I for Fujitsu to rebuild branch reports.
57] transaction data from backups, 11.10 - what are the specific authorisation
ig rise to the further risk of (d) Save as aforesaid, if Post Office requirements (Defence 57(3) - sounds like a
error being introduced into the understands it correctly, the transaction put in to change data)?
branch transaction records. The general thrust of paragraph 21.3 is
Claimants understand that Fujitsu denied. 11.11 ~ how many occasions?
maintained a 'Known Error Log’
relating to some or all of these 50. See above 11.12 did any of the above have the potential to
issues which was provided to the affect the claimants
Defendant, but which has not been
disclosed 57. Paragraph 25 appears to be concerned 11.20 ~ how did FJ go about tracing these
with the editing or deletion of transaction effects/how did they ID bug in first place w/o
25. Further, the Defendant was, by I data input by or on behalf of a amending transactions?
itself and/or via its agent Fujitsu, I Subpostmaster without his or her consent.
able to alter branch transaction Accordingly, Post Office assumes that it is RW ~ 11 refers back to 10, 10 doesn't refer to bugs.
data directly and carry out changes I not concerned with transactions such as
to Horizon and/or transaction data_I Transaction Corrections which are sent to 11.30 - what is the process?
which could affect branch accounts. I branches but must be accepted by or on
behalf of the Subpostmaster before 11.32 ~ how are these BTs readily identifiable?
forming part of his or her branch account. As
to the circumstances in which such 11.40 -JC-1 have seen a statement that PO has
transaction data can be edited or deleted "never consented” to the use of this.
without the consent of the Subpostmaster:
‘AP — if you want to go down this route, need to
(1) Neither Post Office nor Fujitsu has the properly plead your case on fraud. AP—a statement
ability to log on remotely to a Horizon by PO after the event is not a governance question.
terminal in a branch so as to conduct JC=I need to ask that in a different way.
transactions.
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(2) A Post Office employee with "global
user" authorisation can, when
physically present at a branch, use a
terminal within the branch to add a
transaction into the branch's accounts.
The purpose of "Global User"
authorization is to allow access to the
systems for during training and/or
audits. Any transactions effected by a
Global User are recorded against a
Global User ID and are readily
identifiable as such.
(3) Fujitsu (and not Post Office) has the
ability to inject transactions into branch
accounts (since the introduction of
Horizon Online in 2010, transactions of
this sort have been called "Balancing
Transactions"). These transactions do
not involve any removal or amendment
of the transactions entered at the
branch. Their intended purpose is to
allow Fujitsu to correct errors or bugs in
Horizon by cancelling the effect of an
error or bug on a branch's data. They
may be conducted only by a small
number of specialists at Fujitsu and
only in accordance with specific
authorisation requirements. They are
rarely used. To the best of Post Office's
information and belief, only one
Balancing Transaction has ever been
made so as to affect a branch's
transaction data, and this was not in a
branch operated by a Claimant. A
Balancing Transaction is readily
identifiable as such.
(4) There are a small number of Fujitsu
specialists who have certain privileged
user access rights which they could in
theory use to amend or delete the
transaction data for a branch. The
intended purpose of privileged user
11.16 ~ a log of issues in Richard Rolls where the cause
of the discrepancy could not be determined. Did FJ
make changes to Horizon on those particular
questions? AP — we need to understand what Richard
told you.
JC—a separate log/source of data (excel spreadsheet
called issues where we can't determine).
Do FJ have a record of the branches where the branch
was told to stop using the equipment when remote
access was used?
11.71 JC~as I understand it, branch account needs to
be static when change being made
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12 I Ifthe Defendant and/or Fujitsu did have such
ability, how often was that used, if at all?
[GPOC §§21.3, 23, 25; Defence §§48(3)(c),
57)
rights is system support, not the
alteration of branch transaction data.
To have abused those rights so as to
alter branch transaction data and
conceal that this has happened would
be an extraordinarily difficult thing to
do, involving complex steps (including
the writing of sophisticated computer
programmes and circumvention of
sophisticated control measures) which
would require months of planning and
an exceptional level of technical
expertise. Post Office has never
consented to the use of privileged user
rights to alter branch data and, to the
best of its information and belief, these
rights have never been used for this
purpose.
(5)_ Post Office cannot conceive of a reason
why any Fujitsu personnel would have
sought to add, inject, amend or delete
any transactions in any branch accounts
so as to create a false shortfall. It would
for all practical purposes be impossible
for any of them to generate significant
shortfalls without detection and, even
if they were able to do so, they would
be unable to take the benefit of such
shortfalls for themselves.
48. As to paragraph 21:
(3) Paragraph 21.3 bundles together
several different concepts and uses
language that is open to different
meanings and/or misleading. However:
(c) Itis denied that Fujitsu has
implemented fixes that have
affected the reliability of
accounting balances, statements or
reports.
57. See above
Issue 12 appears to be a factual issue
rather than an expert issue.
12.10 Get the one BT
RW - feels like a factual question.
JH—we have agreed it.
Number of KELs that might help us (e.g.) ~ makes
reference to something that can be done.
‘AP —KELs in general (8k) — what are we going to do
with those? Going to review and pull out relevant
ones. 1D shortfall, then split them into buckets.
Identify Peaks referred to and see what they relate to.
Once you start delving into them, can't get through
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13 I To what extent did use of any such facility
have the potential to affect the reliability of
Branches’ accounting positions?
[GPOC §§21.3, 23, 25; Defence §§48(3)(c),
relatively quickly (nightmare is abbreviations; a look
up table will accelerate the process)
JC- if Fi can show us what they do re BT, we can
inject one into the model office. Make enquiries.
57]
14 I How (if at all) does the Horizon system and its I Reply 17. As to the Defendant's Branch Trading Statements, making good Issue 14 appears to be a set of AP = (if at all) present because POL says it doesn't do
functionality: case as to the balancing process and disputing shortfalls factual questions, with possible some of those things.
a. enable Subpostmasters to compare
the stock and cash in a branch against
the stock and cash indicated on
Horizon?
b. enable or require Subpostmasters to
decide how to deal with, dispute,
accept or make good an alleged
discrepancy by (i) providing his or her
own personal funds or (ii) settling
centrally?
c. record and reflect the consequence of
raising a dispute on an alleged
discrepancy, on Horizon Branch
account data and, in particular:
i, does raising a dispute with the
Helpline cause a block to be
placed on the value of an
alleged shortfall; and
ii, is that recorded on the Horizon
system as a debt due to Post
Office?
d. enable Subpostmasters to produce (i)
Cash Account before 2005 and (ii)
Branch Trading Statement after 2005?
enable or require Subpostmasters to
continue to trade if they did not
complete a Branch Trading Statement;
and, if so, on what basis and with
what consequences on the Horizon
system?
[Defence §§42-46; Reply §§17.1-17.2, 21]
and branch trading periods at
paragraph 42:
17.1. the Defendant admits that a
purpose o€ the balancing process
(paragraphs 19.1 of the GPOC and
43(1) of the Defence) was to
‘ensure the early identification and
correction of any errors and
defaults relating to the transactions
and/or to the cash and stock field in
the branches for which the
Subpostmasters are responsible’;
17.2. the Defendant admits that the
requirement to perform a balancing
process was initially weekly, but
was changed in 2005 to 'Post Office
specified periods of 4 or 5 weeks'
(Defence, paragraph 43(1));
21. As to paragraph 12, 39, 40, 45
and 46 of the Defence in respect of
Transaction Corrections issued by
the Defendant and affecting branch
accounts:
21.1. the Defendant's
characterisation of the process as
offering a "choice" to Claimants
whether to accept a Transaction
Correction, and in particular the
Defendant's pleading at paragraph
42. As to the first sentence of paragraph
19, it is denied that the matters addressed
in paragraphs 19.1 to 19.3 "accentuated
the importance of the accuracy of Horizon’
Paragraph 19 addresses requirements
whose purpose is to ensure the proper
discharge of the Subpostmaster's
contractual and common law duties to
account to Post Office for the transactions
they entered into on its behalf and for the
cash and stock it entrusted to their care.
Such requirements are to the mutual
benefit of Subpostmasters and Post Office
in that (amongst other things) they ensure
the early identification and correction of
any errors and defaults relating to the
transactions carried out and/or to the cash
and stock held in the branches for which
the Subpostmasters are responsible.
43. These requirements are as follows:
(1) Subpostmasters are required to
perform a regular "balan
which involves counting all stock and
cash at their branches, comparing it
with the cash and stock indicated on
Horizon and producing (and
confirming) an account of the
transactions undertaken since the last
balancing process and of the cash and
stock held. Initially, Subpostmasters
expert commentary on the answers.
Therefore, two expert reports may
not be the best way to address it.
GPOC 21 raises a number of factual
issues concerning what actually
happened over several years, rather
than what was documented in some
Horizon manuals.
Several sub-paras of 21 seem to
depend on individual claimants and
are therefore out of scope for the
Horizon trial.
Similarly, Defence 43 is largely
about factual history of business
processes outside Horizon.
14.10 Is there a stock transaction/movement report
(or similar?).
14.20 - examples of one-sided transactions — not clear
if SPMR had evidence or if SS found them
somewhere?
AP - SS had a theory that it happened, but could never
evidence it.
JH - PO didn't say it doesn't happen ; AP - obviously,
RW explained that it does earlier.
JC~ one of the first KELs talks about banking
transactions in E26 (inconsistent state where bank has
half). DO1 =a reversal fail.
RW -— high likelihood ~ errors for the guy at the till.
RW — bank agrees to £50 being paid out, transaction
doesn't go through,
JH = complicating factor. £50 withdrawal, transaction
fails, they are given the £50 — should the SPMR have
given out the £50. Branch
JC~ difference between evidence
JH— good example of complexity; a number of ways to
get to shortfall.
AP — could sit down and postulate 1000s of
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39(4) that "A Transaction
Correction notification sent by Post
Office to a branch is a proposal, not
‘an instruction, and it does not take
effect unless accepted by the
Subpostmaster concerned" and that
"[o]n receiving a Transaction
Correction. the Subpostmaster can
either accept the correction or
dispute it" (and similar pleading at
paragraph 12) is misleading and
denied;
21.2. in fact, Horizon operated such
that Claimants were required to
accept Transaction Corrections and
there was no option within Horizon
to dispute an alleged or apparent
shortfall (as admitted at Defence
paragraph 46(1));
21.3. Transaction Corrections were
not proposals, rather the
Defendant instructed Claimants in
the Branch Trading Manual that
Transaction
Corrections were ‘necessary when
branch transaction data does not
clign with client or supplier data ...
Transaction Corrections are
basically electronic Error Notices
informing you of transactions that
have been carried out incorrectly on
the Horizon Online™ system and
not been corrected and ‘they must
be processed before the last stock
unit in a branch balances, otherwise
Branch Trading Period rollover
cannot take place’;
21.4, the option to ‘settle centrally’
in respect of amounts over £150
(Defence paragraph 39(5)) was not
known about by all Claimants, but
(2
(3)
were required to do this weekly, but
2005, they have been required to
do so at the end of each "Branch
Trading Period" (Post Office-specified
periods of 4 or 5 weeks, of which there
are 12 in the year and which, for
convenience, are referred to herein as
“trading periods").
Where this process discloses a shortfall
and the Subpostmaster accepts liability
for the shortfall, he or she is required
to make it good (1) by providing his or
her own personal funds to the branch
or (2) if the amount involved is £150 or
more, by settling it centrally. This
election is made on the Horizon
terminal in branch. By "settling
centrally", a separate entry is added to
the branch accounts which offsets the
value of the shortfall, thereby bringing
the derived cash figure on Horizon in
line with the actual cash on hand figure.
The amount of the shortfall is
transferred to the Subpostmaster's
personal account with Post Office.
‘Arrangements can then be made to pay
off the shortfall.
Where the Subpostmaster disputes
liability for the shortfall, he or she is
required to raise a dispute by calling
the Helpline and in the meantime (if
the amount involved is less than £150)
to provide it from his or her own funds
pending resolution of the dispute or (if
the amount is £150 or more) to settle it
centrally, thereby bringing the branch
accounts into balance. Raising a dispute
causes a block to be placed on the
value of the shortfall that has been
transferred to the Subpostmaster's
personal account with Post Office. The
blocked value is not (and is not treated
possibilities; only ones that go toa peak. A peak anda
fix is made. JC for me it is where they go to peaks
148, Cand D ~ questions of fact - ask the questions.
14E 14,90 can they continue to trade?
14.91 - how long for?
14.92 can you submit a branch trading statement?
CE - answers likely to be in the operating manual
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for the avoidance of any doubt, in
any event the effect of this (on the
Defendant's own case) was to incur
an immediate liability to the
Defendant:
21.5. the limited option available to
Claimants was to contact the
Helpline to raise a dispute. This
‘operation of the Helpline and
advice provided was inadequate
and ineffective for the reasons
pleaded at GPOC and further
herein, and the requirement for
Transaction Corrections to be
accepted as at paragraph 21.2 and
21.3 above applied even in cases
where a dispute was raised, such
that:
(a) Claimants were in any event
required to accept Transaction
Corrections with an immediate
effect on their accounts which
they in fact disputed; and
(b) the Defendant thereby
operated a system which
required Claimants to sign
Branch Trading Statements
when they could not or did not
agree such statements as
correct;
21.6. the Claimants rely on the
Defendant's description at Defence
paragraph 39 as to how Transaction
Corrections are generated
(including specifically at
subparagraph (1) that "Post Office
checks Horizon transaction data
(i.e. data as keyed in to branch
terminals by branch staff) against
data taken from separate sources"),
(4)
(5)
(6)
as) a debt due to Post Office.
These processes are addressed in pages
92 - 99 of the Branch Trading Manual.
The same processes are followed
where the Subpostmaster accepts or
disputes a net gain, with the relevant
transactions being the removal of cash
from the branch or the creation of a
credit on the Subpostmaster's personal
account with Post Office.
Having followed these processes,
Subpostmasters are required to
produce and sign a statement setting
out the quantities and values of the
various receipt and payment
transactions that have been carried out
in the branch during the relevant
period and the cash and stock held in
the branch at the end of the trading
period (called a "Cash Account" until
2005 and a "Branch Trading
Statement" from 2005). Branch Trading
Statements contain the following
statement by the Subpostmaster: "/
confirm that the content of this
balancing and trading statement is an
accurate reflection of the cash and
stock on hand at this branch".
A branch cannot enter (or "roll over"
into) a new trading period without the
Subpostmaster declaring to Post Office
the completion of the Branch Trading
Statement as aforesaid. However,
although Subpostmasters are required
to produce Branch Trading Statements
at the end of each trading period, if
they do not do this, their branches can
continue to trade within the previous
trading period (although Post Office
does not allow them to do so
indefinitely).
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‘and the instructions in the Branch
Trading Manual at paragraph 21.3 I Branch Trading Statements
above as evidence that the
Defendant did not consider or take I 44. As to paragraph 19.1, subject to
into account the possibility that paragraph 43 above:
Horizon transaction data was
affected by bugs, errors orremote I (1) The first and second sentences are
alteration; admitted.
21.7. paragraph 40(1) is denied for I (2) The third and fourth sentences are
reasons aforesaid. Further, when denied, Paragraph 43(1) above is
there was an alleged or apparent repeated as regards the comparison
shortfall, some Claimants were between the derived figures for cash
advised by Helpline operators that and stock shown on Horizon and the
if Horizon was showing a loss, they actual cash and stock as counted by the
were required to make it good/pay Subpostmaster; paragraphs 43(2) and
it immediately; 43(3) above are repeated as regards
bringing Horizon's figures into balance
21.8. without prejudice to above, it with the cash and stock as counted; and
is admitted that the Defendant's paragraph 43(6) above is repeated as
current practice is generally to regards the ability to continue trading
provide specific contact details of without entering a new trading period.
an individual employee (Defence
paragraphs 39(3), 39(6), 40(2) and I Making good
46(4)), but denied this was
previously the Defendant's 45. Paragraph 19.2 appears to be intended
practice, and in any event the to allege that, whenever there is a shortfall
Claimants will aver that where between Horizon's figures and the cash and
persons were identified they were I stock counted by the Subpostmaster: (1)
frequently not available and/or unless some special arrangement is made,
could or did not deal adequately the Subpostmaster is required to make good
with the particular queries raised I the difference; and (2) if he or she does so
and/or did not do so prior to the by settling centrally, the amount of the
obligation on Claimants to rollover I shortfall is treated as a debt due to Post
into the next Branch Trading Office. These allegations are specifically
Period; denied. As explained in paragraph 43 above,
Post Office's procedures provide
21.9. in all or most cases, it is Subpostmasters with the opportunity to
denied that the Defendant dispute liability for shortfalls.
provided adequate information or
evidence as to the reason for the I Disputing shortfalls
correction so as to enable
Claimants to carry out their own 46. As to paragraph 19.3:
investigations into Transaction
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Corrections raised;
21.10. the Defendant's response to
the Claimants! RFl to identify
material changes to the process in
relation to the issuing of
Transaction Corrections and
process of disputing them is vague
and inadequate (for example in not
identifying the change in practice in
the identification of a named
contact, which is repeatedly relied
‘on in the Defence) such that the
Claimants are unable to identify
what material changes have been
made and when;
21.11, the Defendant's account of
the process of investigation and
escalation at paragraph 46(4) of the
Defence is hopelessly vague and
the Defendant's response to the
Claimant's RFI of this paragraph
only obscures the Defendant's case
further. The Defendant is put to
strict proof of the process in fact
adopted and material changes to it,
and the scope and adequacy of the
investigation and communication
with Claimants. The Claimants will
in any event aver that any such
processes were inadequate,
insufficiently timely, and
insufficiently communicated to
them and/or did not work in
practice, including because of the
requirement by the Defendant for
Claimants to sign Branch Trading
Statements and/or accept
Transaction Corrections and/or
move into the next trading period
in order to continue trading and/or
because the Defendant's approach
was substantially to require
(1) It is admitted that there is no "option
within Horizon" to dispute a shortfall, in
the sense that the process of raising
and resolving a dispute does not take
place through the Horizon system. The
process for disputing a shortfall
requires the dispute to be lodged by
calling the Helpline.
(2
It is denied that Subpostmasters are
unable to carry out effective
investigations into the disputed
amounts. So is the allegation that there
were unspecified "limitations" on
Subpostmasters' ability to access,
identify and reconcile transactions in
Horizon and that Horizon had no
“adequate report-writing feature". As
indicated in paragraph 38(2) above,
Horizon provides Subpostmasters with
tools for searching, checking and
reviewing the transactions undertaken
in the branches for which they are
responsible.
(3
There are provisions in Post Office's
Operating Manual as to the process for
disputing discrepancies (see, for
example, page 34 of the Branch Trading
Manual) and it is denied that these
provisions give insufficient guidance
regarding that process. In any event,
the process involves calling the Helpline
and, if further guidance is needed, it is
available directly from the Helpline.
(4) As to the last sentence of paragraph
19.3, itis denied that Post Office fails to
carry out any, or any fair or adequate
investigations into disputed amounts.
Where a shortfall is disputed then the
Claimants' first point of contact would
be with the Helpline. In the case of a
Transaction Correction, the dispute
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Claimants to prove why the
Transaction Correction ought not to
be applied in circumstances where
Claimants had limited access to
data and reports as aforesaid.
would first be raised with the individual
within Post Office who issued the
Transaction Correction notification and
then (if necessary) with the Helpline.
Disputes are generally resolved at this
stage, by Post Office and the
Subpostmaster reaching a common
understanding of the position. But i
this does not happen, the dispute can
be escalated. The steps in the
escalation process, and the Post Office
teams involved, have changed over
time and the specific escalation route
can differ depending on the nature of
the issue raised. However, in broad
terms these would include:
{a) After itis raised with the Helpline,
the issue would generally be
escalated to more experienced and
senior personnel within the
Helpline (or the team issuing the
disputed Transaction Correction)
for further investigation.
(b) If not resolved, the matter would
be referred to a senior person in a
Post Office team responsible for
investigating branch matters,
which is currently the Support
Service Resolution Team. This team
undertakes a further investigation
into the disputed amount, seeks to
identify the reason for it arising
and communicates with the
Subpostmaster concerned.
15
How did Horizon process and/or record
Transaction Corrections?
[Defence §§12, 39-40, 45-46; Reply §21]
Reply 21. See above
12, Post Office denies that Claimants could
not effectively investigate losses in their
branches. Subpostmasters had access to
line by line data on the transactions they
undertook. Moreover, they had access to
training, operations manuals, helplines and
in-branch support if they wanted. Post
Office also undertook its own accounting
The technical issue of how Horizon
processes transaction corrections is
embedded in a matrix of facts about
business processes (and how they
actually operated), as pleaded at
Defence 39.
Input (there is a gap)
How do TCs enter the system and how do they
influence a branches’ accounts.
JC caught elsewhere?
JH ~ practical and commercial reality
(00+ people
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reconciliations, where possible matching a
Subpostmaster’s records against other
records provided by third parties, and then
notifying Subpostmasters of discrepancies
found and allowing them to choose
whether to accept or dispute those
discrepancies.
Transaction Corrections
39, Paragraph 18 refers to transaction
corrections. One of the safeguards against
errors by Subpostmasters (or their staffis a
process by which Post Office proposes
corrections to a branch's accounts
("Transaction Corrections"). These are
typically generated in the following way:
(1) Post Office checks Horizon transaction
data (i.e. data as keyed into branch
terminals by branch staff against data
taken from separate sources. For
example, Post Office client banks
provide their own records of
transactions carried out in Post Office
branches, which are transmitted
directly from the chip and pin devices
used in branches to the banks and Post
Office compares these to the
transaction data on Horizon.
(2) Where there is a discrepancy between
the two sets of data, Post Office
reviews the available data with a view
to determining whether the branch
staff have probably made an error that
requires correction (and it may contact
the relevant Subpostmaster for further
information to assist in that
determination). Where this is the case,
Post Office will generate a Transaction
Correction notification which is sent to
the relevant branch via Horizon. For
example, where a cheque deposit into a
It would be useful if the experts
could start with an agreed set of
such facts, rather than dig them out
individually.
crunching data.
15.20 - In order for H to process a TC, what
information is entered into it?
JH — bigger point - SPMR the only data they get is
from Horizon. They have other info (minds, safe,
paperwork). Should there be more channels of data
that link into reconciliation piece.
JH—a TC must be accepted by the end of the month.
JH volume is roughly 12k per month, 10,000s per
months. AP — this is why it is for another trial,
JC-would like to see origins of TC
JH - to what extent does inability to investigate X, Y
and Z affect strength of opinion?
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(3
(4)
(5)
bank account is keyed in on Horizon as
a £100 credit but the true amount of
the cheque is £90, a Transaction
Correction with a value of £10 debit is
generated.
A Transaction Correction notification
includes (i) a description of the
transaction to be corrected, (ii) the
contact details of an employee of Post
Office who will provide further detail if
required, (ii) typically, the outline
reason for or nature of the correction,
and (iv) sometimes, evidence
substantiating the proposed correction.
A Transaction Correction notification
sent by Post Office to a branch is a
proposal, not an instruction, and it does
not take effect unless accepted by the
Subpostmaster concerned. On receiving
a Transaction Correction notification,
the Subpostmaster can either accept
the correction or disput
(On the Horizon screen, there are two
ways for a Subpostmaster to accept a
Transaction Correction. He or she may
“accept” the Transaction Correction:
this immediately increases or decreases
the cash or stock position (as
appropriate) in the branch's accounts
as recorded on Horizon. Alternatively, if
the amount of the Transaction
Correction is £150 or more, he or she
may “settle it centrally": this causes the
amount of the Transaction Correction
to be transferred to his or her personal
account with Post Office. Unless a
dispute is lodged with Post Office (see
below), he or she thereby accepts the
validity of the Transaction Correction
and Post Office will in due course pay
or collect the relevant amount to or
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from the Subpostmaster. This process is
addressed in page 30 of the operating
manual entitled "Branch Trading:
balancing and dispatch of documents"
("Branch Trading Manual").
(6
If the Subpostmaster wishes to query or
dispute the Transaction Correction, he
or she should contact the person
identified in the Transaction Correction
notification.
7
This process is identified at page 34 of
the Branch Trading Manual. If, having
discussed the matter and reviewed any
further information provided by the
person identified, the Subpostmaster
wishes to dispute the proposed
Transaction Correction, he or she
should accept it or settle it centrally
and then lodge a dispute with the Post
Office by contacting the Helpline.
Where it is settled centrally, the
amount of the Transaction Correction is
transferred to the Subpostmaster's
personal account with Post Office and a
block is placed of the amount
transferred to the personal account
whilst the dispute is resolved.
40. As to paragraph 18:
(1) The first sentence is denied. Post Office
does not require that a Transaction
Correction be accepted unless proven.
by the Subpostmaster not to be
correct.
(2
Save for the reference to “limited”
reports (which is denied as indicated in
paragraph 38 above), the second
sentence is admitted. However:
(a)__ every Transaction Correction
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‘comes with contact details for a
person at Post Office who can
provide more information and a
‘Subpostmaster can in any event
contact the Helpline referred to
below to obtain more
information;
{b) depending on the subject matter
of the Transaction Correction, the
Subpostmaster may hold
corresponding paper records in
his or her branch which he or she
can and should check; and
(c) _notall Transaction Corrections
require further information (for
‘example, a Transaction Correction
could be generated for a missing
cheque and the cheque might be
found in the branch).
Making good
45, Paragraph 19.2 appears to be intended
to allege that, whenever there is a shortfall
between Horizon's figures and the cash and
stock counted by the Subpostmaster: (1)
unless some special arrangement is made,
the Subpostmaster is required to make good
the difference; and (2) if he or she does so
by settling centrally, the amount of the
shortfall is treated as a debt due to Post
Office. These allegations are specifically
denied. As explained in paragraph 43 above,
Post Office's procedures provide
Subpostmasters with the opportunity to
dispute liability for shortfalls.
Disputing shortfalls
46. As to paragraph 19.3:
(1)_It is admitted that there is no "option
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(2)
(3)
(4)
within Horizon” to dispute a shortfall, in
the sense that the process of raising
and resolving a dispute does not take
place through the Horizon system. The
process for disputing a shortfall
requires the dispute to be lodged by
calling the Helpline.
It is denied that Subpostmasters are
unable to carry out effective
investigations into the disputed
amounts. So is the allegation that there
were unspecified "limitations" on
Subpostmasters' ability to access,
identify and reconcile transactions in
Horizon and that Horizon had no
“adequate report-writing feature". As
dicated in paragraph 38(2) above,
Horizon provides Subpostmasters with
tools for searching, checking and
reviewing the transactions undertaken
in the branches for which they are
responsible.
There are provisions in Post Office's
Operating Manual as to the process for
disputing discrepancies (see, for
example, page 34 of the Branch Trading
Manual) and it is denied that these
provisions give insufficient guidance
regarding that process. In any event,
the process involves calling the Helpline
and, if further guidance is needed, it is
available directly from the Helpline.
As to the last sentence of paragraph
19.3, itis denied that Post Office fails to
carry out any, or any fair or adequate
investigations into disputed amounts
Where a shortfall is disputed then the
Claimants’ first point of contact would
be with the Helpline. In the case of a
Transaction Correction, the dispute
would first be raised with the individual
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within Post Office who issued the
Transaction Correction notification and
then (if necessary) with the Helpline.
Disputes are generally resolved at this
stage, by Post Office and the
Subpostmaster reaching a common
understanding of the position. But if
this does not happen, the dispute can
be escalated. The steps in the
escalation process, and the Post Office
teams involved, have changed over
time and the specific escalation route
can differ depending on the nature of
the issue raised. However, in broad
terms these would include:
(c) After itis raised with the Helpline,
the issue would generally be
escalated to more experienced and
senior personnel within the
Helpline (or the team issuing the
disputed Transaction Correction)
for further investigation.
If not resolved, the matter would be
referred to a senior person in a Post Office
team responsible for investigating branch
matters, which is currently the Support
Service Resolution Team. This team
undertakes a further investigation into the
disputed amount, seeks to identify the
reason for it arising and communicates with
the Subpostmaster concerned.
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