WITN05610100 Tom Fitzgerald - First Witness Statement

Evidence on official site

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Witness Name: Tom Fitzgerald
Statement No.: WITN05610100
Dated: 4" April 2023

POST OFFICE HORIZON IT INQUIRY

FIRST WITNESS STATEMENT OF TOM FITZGERALD

I, TOM FITZGERALD, will say as follows...

Please set out an overview of your role(s) within the Post Office

1. I have performed a variety of roles within Post Office. These are listed below.

Dates prior to 2000 I have included these to the best of my knowledge.

Counter clerk (Aug 1984 — 1988)

Area support Officer — Crown Post Office Branches (1988 — 1989)
Assistant Branch Manager (1989 — 1990)

Branch Manager (1990)

Project support ECCO+ project (1990 — 1992)

Test Support ECCO+ project (1992 — 1993)

Operations Manager (1993 — 1994)

Business Analysis & IT Interface Manager (1994 — 1995)
Project Manager (1995 — 2000)

Business Analyst (Aug 2000 — Jun 2008)

Business Solutions Manager (Jun 2009 — Oct 2011)
Principal Business Analyst (Oct 2011 — May 2017)

Non-Post Office roles — (May 2017 — Sept 2018)

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e Product Manager (Head of Identity Propositions) — (Sept 2018 — Mar
2021)

e Technical Integration Manager (current role) — (Mar 2021 — present)

Please describe any qualifications you had.

2

3.

English, History and Religious Education - O Levels

Mathematics, Computer Studies, Spanish - CSE’s

Please set out any training you received.

4.

I have undertaken all and any training required to undertake each role. I cannot
recall all these courses, other than those listed below.

I have attended external courses for Project Management, Business Analysis and
Client Relationship Management.

I have also completed all and any training as specified within the Post Office
Success Factors training tool. This includes, but is not limited to, anti-money
laundering, competition law, anti-bribery and corruption, fire safety, information
security and data protection, contract management, group litigation awareness,
health & safety essentials, health & safety personal safety and wellbeing, modern
slavery & human trafficking, Postmaster complaint handling (completed on
09/02/2022 — this course was a business wide course that was designed to raise
awareness of what Post office employees should do if a Postmaster complains
and to help understand the key principles of the Postmaster complaint handling
policy), procurement, speaking up with confidence, and a week in the life of a
Postmaster.

I have also undertaken Horizon training courses to enable me to support our

Branches during Christmas peak periods and period of industrial action. I can not

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recall exactly when I undertook Horizon training but it would have been over 10

years ago.

Please describe any career progression within the Post Office.

8. As defined within paragraph 1 above I have undertaken several roles within Post
Office.

9. My career started on the Post Office branch counter at Kings Cross Post Office
on 13' August 1984. Following the completion of the eight-week training course I
was assigned a training branch where I spent one year training. On completion of
my training I was assigned as a reserve Postal Officer. A reserve Postal Officer
within the North London Counter District was used to fill resource gaps across the
Post Office Crown branch network. I was a Postal Officer for two years
whereupon I was assigned my permanent Branch. My permanent branch was
Swiss Cottage in London NW3. Whilst at my permanent Branch office I was
temporarily promoted to Postal Office with Allowance (POA). The POA duty
performed additional back-office activities such as stock checking and completing
the weekly cash accounts. At this time (circa 1988) all branch accounts were
completed manually on paper spreadsheets. I was then assigned to another Post
Office (Belsize Park London NW3) as the temporary Branch Manager (Grade
Temp/Counter Manager Grade 3 CM3). Following this I returned to my
permanent branch as Assistant Branch Manager (permanent CM3). I applied for
a role as a Project Support on the ECCO+ project. I was successful in my
application. I cannot be specific on the dates that I started this role, it was circa
1990.

10.When the ECCO+ project finished I was assigned a role as an Operations
Manager. I applied for and obtained two promotions as an Operations Manager.

Initially I was promoted to Counter Manager Grade 2 (CM2) and then Counter
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manager Grade 1 (CM1). An operations manager at the time was responsible for
communicating to the Branch network new products and service and when there
had been any changes to these specific products. At this time, I was Operations
Manager for products called local schemes, which included the sale of Home Care
stamps on behalf of local authorities, sale of local ticket and travel schemes and bill
payment schemes. As an Operations Manager I would deploy these new or
changes to these services into the Post Office network. I cannot be sure of the
exact dates I was in this role but it would have been between 1994-1998.

11.As part a business reorganization, I cannot be exact on these dates, I was
temporarily appointed as a Business Analysis & IT Interface Specification
Manager, (temporary Scale Band 9 SB9). Whilst undertaking this role I was
interviewed and successfully permanently appointed Scale Band 9 SB9. The
Business Analysis and IT Interface Specification Manager role was responsible
for a team of six Business Analysts that developed business requirements for
Clients that were looking to use Post Office branches to deliver their products. I
was performing this role between 1996 — 1998, I am not sure of the exact dates.

12.1 then undertook several roles including Project Manager and Business Analyst
between 1998 — and 2008. I then applied for and successfully obtain the role of
Business Solution Manager (Scale Band 8 SB8) in June 2008. The Business
Solutions Manager was responsible for working with clients and Post Office
stakeholders to define client and Post Office requirements in order to develop
new or changes to Post Office services. I undertook roles at this grade until I left
Post Office in May 2017. I re-joined Post Office in September 2018 as a Product
Manager at Level 4.

13. Following a Post Office reorganisation in March 2021 I was appointed to my
current role Head of Technical Integration for Pick Up Drop Off (PUDO) Carriers.

This is a Level 4 role.
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Advice and Assistance

Please provide an overview of what contact you had with subpostmasters or

managers and assistants working in Post Offices, if any.

14. The various roles that I have performed I have had direct contact with
Postmasters, Managers and Assistants working in Branches. My contact with
Postmasters would have been to gather feedback on proposed new services or
to answer any questions they had about a particular transaction. My contact
would have been limited to products and not the Horizon IT system specifically.

15.As an Operations Manager in Post Office your role will be to manage the
“operation” of some of the Post Office’s products. The Operations Manager must
understand how the product is undertaken and manage any changes to the
product operation, whether these are Post Office or Client driven. In most cases
these changes are client driven. As an example, a client may wish to change a
form that is completed by a customer and accepted by a Branch. This change
would have to be documented and communicated to Branches so that the
change could be deployed successfully.

16.Any advice I would have provided to Postmasters, Managers and Assistants
working in Post Office branches would have related to the products they were
transacting.

17.Contact with Postmasters, Managers and Assistants working in Post Office
branches would have been direct as part of telephone calls, at exhibitions,

conferences etc or via email, text messages, WhatsApp etc.

Please describe whether you were responsible for providing subpostmasters or Post

Office branches with advice or assistance.

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18.1 would have been responsible for providing Postmasters with advice and / or
assistance relating to the products that they were undertaking. For example, I was
the Operations Manager for Automated Payments. Automated Payments allowed
clients to issue their customers with payment cards that enabled them to make
payments towards their utility bills. If a Postmaster had a query on the minimum
amount that could be paid, I would provide advice on the individual client's
transaction parameters or I would signpost them to the relevant publication where
the information could be found.

19. This statement would be true for any products that I managed the operation for.

When issues were raised, how did you escalate these difficulties?

20. The only issues that I would become involved with would relate to the transaction
of a product. If I was unable to resolve the product query I would either escalate
to my manager to help me resolve or if the Postmaster required additional help
and potentially a branch visit, I would contact then Area Manager. I cannot recall

any instances where I have had to escalate and issues relating to the product.

Please specify, if you have not already done so, how often any difficulties involved

the Horizon system.

21.1 would not be involved in any issues that related to the Horizon system. My
expertise relates to how the products are transacted on the Horizon system. If a

Branch was unsure how to process a transaction, I could help.

Were there any steps that you thought should have been taken in response to any

concerns that you raised that were not?

22.No.

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Was there anyone who you felt could have done more to assist or make things better

for subpostmasters.

23.From a product design and implementation perspective I think that we all have a
responsibility to make things easier for Postmasters. In the main I believe that for
product design and implementation, my area of expertise, we tried to make this
as easy as possible for Branches to undertake correctly. Branch instructions
would detail the Horizon process and show the relevant Horizon screens. The
Horizon transaction itself would also contain transaction prompts and instructions
on how to undertake transactions correctly.

24.1 could not identify anyone who I felt could have done more to assist or make

things better for Postmasters.

Training
If you were responsible for managing the contracts of subpostmasters, set out what

steps you took to ensure that individuals felt confident with using Horizon.

25.1 was not responsible for managing Postmaster contracts.

If someone said that he or she did not feel wholly confident with using Horizon, what

steps did you take to assist them?
26.1 cannot recall ever having had to respond to this question from a Postmaster. If it
did arise, I would have referred them to the Post Office helpline or their Area

Manager for further assistance.

Please explain whether you thought that any improvements could have been made

to the training received by subpostmasters.

27.My responsibility would have been to develop the training for Post Office products

that I was responsible for. Any training received would have related to these
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products. As an Operations Manager and latterly as a Product Manager I would
have liked Horizon to provide a more interactive training methods so that training
could be delivered directly to the Horizon terminal using online tools.

28.I have not been involved in any training relating to any errors or issues with the

Horizon system.

Errors with the Horizon System
Please explain whether you were aware of any issues or problems with the Horizon

system.
29.Other than what has been identified as part of the Horizon Inquiry in 2020. I am

not aware of any issues or problems with the Horizon system.

If so, please set out who you received this information from or how you came to be

aware of these issues and how widely known you consider them to have been.

30.1 would not be made aware of any issues or problems relating to the Horizon
system. If the problem related to one of my products, I would be made aware,
these queries would usually be how the transaction was to be undertaken, pricing
or where stock was obtained from. This would usually be through the Branch
contacting the Post Office Helpline and not normally from Postmasters direct.
When a new product was implemented, I may get a couple of calls. If the Helpline
could not resolve the query, they would contact me. If Postmasters had problems
with the Horizon system in general, these would not be directed or could they be
answered by me. I believe that these would be managed and triaged by the

Helpline.

How did this knowledge impact upon how you dealt with subpostmasters or Post

Office managers or assistants working in Post Office branches.
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31.Any issues that related to products that were routed through to me would me be
managed. There would be no impact on the way that I dealt with Postmasters.

32.1 would not be involved in any issues relating to non-product Horizon issues.

Resolution of Disputes

Please explain whether you were involved in or party to any disputes between the

Post Office and subpostmasters regarding any alleged shortfalls of money.

33.1 was not involved in any disputes between the Post Office and Postmasters.

If so, please describe the process by which any disputes were raised and resolved.

Please specify any individuals you know to have been involved .

34.Not applicable.

Please describe whether you are aware of any contact or input from Fujitsu in the

resolution of any disputes. If so, please provide details including the names of

relevant individuals from Fujitsu.

35.To the best of my knowledge I was not involved in the resolution of any disputes

into the Horizon system.

Please give your view on whether there could have been any improvement in this

process. Please identify who would have been responsible for implementing any

improvement you suggest.
36.1 was not involved in any improvements to the resolution of any disputes process.
My roles within Post Office have been to develop new client products.

Are there any other matters that you consider the Chair of the Inquiry should be

aware of?

37.Nothing from my perspective.
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Please see document: FUJ00001858. Please describe this document and the kinds

of ad-hoc services would be requested via this contract?

38.1 was an optional/ for information only reviewer of this document. The document
looks to be standard change control document that was used between Post
Office and Fujitsu Services. As the document relates to AP (Automated

Payments) we had several clients that utilised the AP functionality, typically, I

believe, that these would be bill payment clients. If these clients required changes

to their interface, change of receipt of files frequency, file destination etc these
would be simple changes to make. The document looks to support the

implementation of a process that could be used to engaged Fujitsu Service

without completing a formal change request. This would allow small changes for

client services to be implemented quickly and relatively low cost to Post Office

and our Clients.

Please see document: POL00039624. Please outline the Service Communications

Plan (S60) and your involvement in the creation and rollout of this project. Was the

project, in your view, successful?

39.1 was involved in the S60 project because of the implementation of the
Automated Payment Additional Data Capture (AP ADC) capability, including the

development of the DVLA online system.

40.AP ADC was developed as a generic capability that could be used to create new

products and services for our clients, both new and existing. This capability

created a toolbox of data sets that could be strung together to design a new

service. For example, if a client wanted to automate and remove the need for the

Post Office to accept and process a paper application the AP ADC capability

would allow these details to be captured electronically and transferred to clients

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as an electronic data transmission. This capability was used to automate the
DVLA transaction and has been used for many other clients. From my
perspective the deployment of the AP ADC capability within the S60 release has
been successful as to date we are still using the AP ADC capability to deliver

client services for Branches.

Please explain background and nature of the IMPACT programme and your

involvement in it. Without limiting your answer, please provide the following details:

a. By what date were the changes proposed by the IMPACT programme first raised

and by who raised them; and b. What were the main business objectives of the

IMPACT programme.
41.1 was not involved in the IMPACT programme. Although it was part of the S60
release my involvement was in relation to AP ADC and DVLA Online projects

within this programme.

Please see document: FUJ00089971. Please can you explain your involvement in

this report.

42.1 do not remember contributing to this document because it relates to the Branch
trading and back-office functions, which were not within my role responsibility.
Having read through the document it does refer to the capture of additional data
as part of a Branch transaction that has the potential to reduce downstream
manual processing, ref Overview 3.2.1 para 17 and 6.2 Overview — Other Data
Capture.

43.AP ADC was the capability that could be used to automate these existing manual
processes. I was likely to have been involved to understand which client services
could utilise the AP ADC capability and if the relevant Post Office Client Manager

and Clients respectively would be willing to change their current service so that

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they may be more efficient. I note within para 6.2 Overview — Other Data Capture

that the product re-engineering element of this project was taken out of scope.

Please explain the process that led to the decision to remove the ability of branch

staff to post discrepancies to a suspense account and then roll into a new trading

period. Without limiting your answer, please provide the following details: a. Who

was involved in making this decision; b. What factors were taken into consideration

when deciding whether to implement this decision; and c. What, if any, tests were

carried out to determine the likely business effect of implementing this change.

44.1 was not involved in the decision to remove the ability of branch staff to post
discrepancies to a suspense account and then roll into a new trading period. My

involvement on S60 was related to the deployment of AP ADC and DVLA online.

Please see document: POL00031810. Please set out what information you had

about the problem(s) described in this document. Please describe the correction

implemented to fix it_and whether it was, in your view, successful?

45.1 would not have been involved in this type of business change. I am not sure
why I would have been copied into the email dated 21/05/2022. I can only
assume that this was for information only. I could not say if this problem was fixed

or not and if it was, whether this was successful.

Please see document POL00022841 at paragraphs 367 - 376. Were you aware of

this issue? Please describe any involvement that you had in relation to this bug.

46.To the best of my knowledge I was not aware of this issue and would therefore

have had no involvement.

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Please see document: FUJ00117941. a. Please can you explain the intranet platform

trialed _in the report and your involvement in this project. Why was the decision taken

not to roll out this interface across all Post Office branches? b. Do you think the

training provided to the post offices trialing this product was sufficient? Why? c.
Please can you explain the issue that you investigated in relation to the Passport

Application Receipt referenced on page 20?

47. I do not recall the project referred to in document: FUJ00117941, but I can see
from reading the document that I was consulted on how Post Office could
automate client services. In general release S60 provided Post Office with the
ability to automate existing paper-based transactions, by having the capability to
capture additional customer or client details as part of a Branch transaction. This
capability was referred to as AP ADC. AP ADC was being used to automate
services and transfer data to clients using dedicated interfaces/ connections and
not through Post Office intranet, as the project was trialing. I do not recall exactly
what was undertaken for passport application receipts, but I suspect that we
would have looked at how the paper receipt could have been removed to
generate a printed customer receipt, as opposed to a handwritten receipt. I
assume that it would have been more of an operational improvement than
resolving a technical issue. I am unable to comment on whether the training

would have been sufficient.

Please see document: POL00002918. Please outline the issue this document refers

to and whether, in your view, this issue was resolved satisfactorily? Please describe

how the working relationship between Atos, Fujitsu and POL was at this time.

48.In April 2017 I was working as a Principal Business Analyst within the Financial
Services team in Post Office. The Drop and Collect and the Home phone and

Broadband products would not have been part of my portfolio. I assume that I
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was copied into the emails for information, because there may have been a
knock-on effect on other projects that ATOS were managing for me at the time.
Referenced in bullet point 1 in the email dated 27th April 2017 13:32. I am unable

to comment on whether the issue was resolved satisfactorily.

Statement of Truth

I believe the content of this statement to be true.

Signed::..

Dated: 4" April 2023

Index to First Witness Statement of Tom Fitzgerald

Document
Description
Service Description for AP Client
1 FUJ00001858 ‘Ad-hoc Service v.1.0 POINQ0008029F
Communications Plan Release
2 POL00039624 $60 (v.0.1) POL-0036108
Branch Trading Reporting,
Management and Control and
3 FUJ00089971 Transaction Management
Conceptual Design (V1.0)
Email from Andrew Perkins, LFS
Product Manager at Post Office
4 I POLO0031810 I Ltd, to Nicholas Samuel, POCL, POL-0028712
re 'Change to stock unit cash on
hand total time' (CCN965)

INo. I URN Control Number

POINQ0096141F

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Technical Appendix to Judgment

POL00022841 (NO 6) "Horizon Issues" POL-0019318
Horizon Additional Content Trial

FUJ00117941 Report & Findings POINQ0124113F
Email from David Randel to

POLO0002918 I /@80n Black; Re: drop and go - vis00003932

checkpoint approval to release
for pilot

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