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Witness Name: David Jones
Statement No: WITN06770100
Dated: 22/3/2023
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF DAVID JONES
I, David Jones, will say as follows:-
INTRODUCTION
1. I am a former employee of ICL Pathway and held the position of
Designer/Developer.
2. This witness statement is made to assist the Post Office Horizon IT Inquiry
(the “Inquiry”) with the matters set out in the Rule 9 Request dated 17%
January 2023 (the “Request’).
3. In this witness statement I adopt the headings and paragraph numbers of the
questions in Appendix 1 to the letter from the Inquiry dated 17" January
2023.
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I should say at the outset that I have very little clear recollection of the matters
referred to in the questions which have been put to me. That is partly
because of the passage of time, the matters occurred more than 20 years
ago. It is also because, as explained below, I had very little involvement in
the aspects of the Horizon system which are of interest to the Inquiry.
Nonetheless, in this witness statement, I have sought to be as helpful to the
Inquiry as I can be.
BACKGROUND
3.
I have been asked to set out my professional background and I can confirm
it is as follows.
I worked in several IT organizations from approximately 1989 before joining
ICL in approximately 1991 via a subsidiary company Omnia, which
specialized in Branch System software for UK building societies using ICL
hardware. Omina became part of ICL Financial Services in approximately
1993, where I continued to work until 1996.
In respect of my role in relation to the Horizon IT Project, I can confirm I
moved to ICL Pathway, initially on a three-month secondment, in
approximately June 1996 as a Designer/Developer working on the
DSS/Benefit Payment Card project within Horizon.
As I recall, there were at the time two planned aspects of Horizon. Firstly,
there was EPOSS which was developed and ultimately delivered to the Post
Office. But also, secondly, there was planned to be a separate system known
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as “Payment Card Functions” (or “PCDF”). These functions supported the
Benefit Encashment Service (or “BES”). Eventually the development of
PCDF was discontinued and nothing was delivered.
I was almost entirely dedicated to the PCDF system. Although my
recollection of the actual delivery phases is limited, I do recall there was a
point when a new set of requirements were issued which required new
designs and software to be written to enhance PCDF. At this stage I was
responsible for identifying, specifying, and estimating these changes to
PCDF with the development work passing to a team from the ICL Centre Of
Excellence in Manchester.
I continued in this role until the termination of the DSS/Benefit Payment Card
project in 1999, when I was reassigned to the Automated Payments System
(the “APS”), which was a discrete part of Horizon. APS was responsible for
bill payments on Horizon. As far as I am aware, no serious bugs were found
in relation to APS. I have few memories of this period but I assume that I
performed a similar design role in relation to APS as I did in respect of the
PCDF system.
The one exception to this was for a brief period (perhaps three to four weeks)
in I believe 1999 when I was called into what was known as the “EPOSS
Taskforce”, a team to seek to identify and resolve bugs in the Horizon
system. This was an intensive period of work but I cannot remember any
details from this period.
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10.
11.
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In April 2001, I joined Escher Group as Support Manager responsible for a
team of technicians supporting the Escher software for customers around the
world. One of those customers was Fujitsu but I do not recall any individual
issue that was raised by Fujitsu with Escher in relation to the Horizon project.
I moved out of that role approximately 12-18 months later and subsequently
had no further involvement with the Horizon project.
I have been asked to set out anything else I wish to say that is relevant to my
roles at Fujitsu and Escher Group Ltd I can confirm that my only involvement
with EPOSS was as part of the EPOSS Task Force referred to above.
THE DEVELOPMENT OF HORIZON
12.
13.
I have been asked to consider document ICL Pathway: Pathway to HAPS
Application Reference Specification (Horizon release 2+) dated 10/04/2000
(FUJ00001374), ICL Pathway Generalised API for OPS/TMS v1 Appendix A
dated 10/04/2000 (FUJ00001378) and CSR+APS Processes and
Procedures v 4.0 dated 12/12/2000(FUJ00001497).I can confirm that I can
see that my name is included in these documents but I have no recollection
of the detail within them or having worked on them.
I have been asked to set out my involvement with the development of
Legacy Horizon, I can confirm that my involvement was limited to -
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14.
15.
16.
17.
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e the design and development of Payment Card Functions (PCDF) for
the DSS/Payment Card system within the overall project;
e adevelopment resource for the EPOSS Task force for a period of a
few weeks; and
* as part of the APS team in what I believe was a design capacity.
I have been asked to consider a Report on the EPOSS PinlCL Task Force v
1.0 dated 14/05/2001 (FUJ00080690) I can confirm that I was brought in as
a development resource for the EPOSS Task Force and fixed several bugs
during that period. I do not recall any specific detail of the work I completed
while on the Task Force.
I recall working on the EPOSS Task Force for a period of approximately three
weeks as I was required to return to my existing PDCF work. I do not recall
being aware of or discussing the proposal to re-write the EPOSS software
during this time.
My only knowledge of problems with EPOSS was being included in the
EPOSS Task Force event and my awareness of the large number of
outstanding EPOSS bugs.
One other point of awareness of concerns with EPOSS was when I was
asked directly by the Development Director to provide details of the total
number of lines of code within PDCF. I understood this was to be used as a
bugs vs lines of code comparison between the sets of software.
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18.
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I have been asked to consider FUJ00077932, FUJ00077938,
FUJ00077943, FUJ00077947 and FUJ00077951, which are working group
meeting of CRS+ Working Group and to confirm my involvement. I can
confirm that I have no recollection of the CRS+ Working Group, the reason
for its formation or who attended the meetings.
IDENTIFICATION OF BUGS, ERRORS AND DEFECTS
19.
20.
21.
22.
As regards paragraph 5, in respect of providing technical support, advice or
assistance to postmasters, I can confirm that I had no involvement in any of
those activities.
I have been asked to explain the purpose(s) of the “Known Error Log” or
“KEL” database, how it operated and who had access to it, I can confirm that
I have no recollection of the KEL database other than I do recall the name
being used during the Horizon project.
I have been asked whether the KEL system was adequate for that / those
purpose(s), I can confirm that I have no recollection of the KEL system so I
am unable to answer the question.
I have been asked to describe the process a person would follow to search
the KEL database to determine if a similar error or problem had arisen before,
I can confirm that I have no recollection of the KEL database so I am unable
to answer the question.
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23.
24.
25.
26.
27.
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I have been asked to explain how support services would provide support in
relation to a suspected bug, error or defect in third-party software such as
Riposte, I can confirm that I did not work in support services so I am unable
to answer the question.
I have been asked to set out the identification and rectification of the specific
bugs, errors or defects listed, I can confirm that I have no recollection of any
bugs or issues that had the potential (a) to cause apparent discrepancies or
shortfalls in branch accounts or (b) undermine the reliability of the Horizon IT
System accurately to process and to record transactions.
I have been asked to set out the process Fujitsu would follow when a bug,
error or defect was identified, I can confirm that I have no recollection of this
process and do not recall being involved in such a process.
I have been asked if the Post Office or Fujitsu's ability to identify and rectify
bugs, error and defects was adequate, I can confirm that I have no
recollection of this process so I am unable to provide an opinion. Moreover,
I do not think that I would at any time have had sufficient overview or
knowledge to determine whether they were adequate.
I have been asked whether the information passed to sub postmasters was
adequate, I can confirm that I have no recollection as to what information was
passed to sub postmasters so I am unable to provide an opinion. Moreover,
once again, I do not think that I would at any time have had sufficient
overview or knowledge to determine whether they were adequate.
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28. I have been asked, with hindsight whether the Legacy Horizon and / or
Horizon Online was robust, I can confirm that I do not have sufficient
knowledge of either system to be able to provide an opinion.
29. Finally, I am not aware of anything else of which I think the Chair should be
aware.
Statement of Truth
I believe the content of this statement to be true.
Dated: 22/3/2023,
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Index to First Witness Statement of David Jones
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URN
Document Description
Control Number
FUJ00001374
ICL Pathway: Pathway to
HAPS Application Reference
Specification (Horizon Release
2+) dated 10/04/2000
POINQ0007545F
FUJ00001378
ICL Pathway Generalised
API for OPS/TMS_ v1
Appendix A dated 10/04/2000
POINQ0007549F
FUJ00001497
CSR+ APS Processes and
Procedures V 4.0 dated
12/12/2000
POINQ0007668F
FUJ00080690
Report on the EPOSS PinlCL
Task Force V 1.0 dated
14/05/2001
POINQ0086861F
FUJ00077932
Minutes of CSR+ Working
Group Meeting no. 13 on
02/02/00
POINQ0067520F
FUJ00077938
Minutes of CSR+ Working
Group Meeting No.15 on
01/03/2000
POINQ0067526F
FUJ00077943
Minutes of CSR + Working
Group Meeting on
15/03/2000
POINQ0067531F
FUJ00077947
Minutes of CSR+ Working
Group Meeting of 29/03/2000
POINQ0067535F
FUJ00077951
Minutes of CSR+ Working
Group Meeting No.18 on
12/04/2000
POINQ0067539F
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