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Witness Name: Jessica Barker
Statement No.: WITN09810100
Dated: 25 November 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF JESSICA BARKER
I, Jessica Barker, will say as follows
INTRODUCTION
1. I ama former contractor of the Post Office Limited (“POL”) working on
the Horizon Initial Complaint Review and Mediation Scheme (“the
Scheme”); I held the position of Mediation and Information Analyst.
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 03 October 2024 (the “Request”). I instructed Olliers Solicitors to
assist me with the preparation of this statement.
BACKGROUND
3. I have been asked to set out my educational and professional
qualifications, as well as details of my career to date.
4. Iam educated to university level and hold both a Bachelor of Arts and
Master of Arts degree. I also undertook a Postgraduate degree in Civic
Design with the School of Engineering at the University of Liverpool.
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Having completed my studies, I worked for a cyber security firm called
Templar Executives from 2011 until 2013 when I decided to become an
independent contractor albeit still working within the field of cyber
security consultancy.
My work at this time focused on the provision of information security
training and policy services and I tended to secure work via
recommendations and networking.
This was how I came to work on the Scheme. I was approached by
Belinda Crowe through Alexander Mann Solutions. We had worked on
some projects together with my previous employer.
To the best of my recollection, Belinda told me that the role would
involve providing support to a team being established to run the
mediation scheme intended to find a fair resolution to claims brought by
Sub-Postmasters (“SPMs”) in respect of the Horizon IT System.
So far as I can remember, I submitted my CV and had a telephone
interview with Belinda Crowe before beginning the contract in
December 2013.
10. The contract was initially intended to be a six-month fixed term
11.
engagement which was subsequently extended so that I ended up
working on the Scheme until June 2015.
It was expected that my role would focus on the information security
processes and training for the Scheme, but this expanded to include
more general administrative functions including arranging meetings,
proofreading documents and ensuring that all parties were aware of
pending deadlines and their obligations re the same.
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12.When my contract ended, I continued working as an independent
contractor before setting up my own small cyber security company
which I now run from the United States of America, having relocated
with my family in 2023 due to greater business opportunities and
frankly better weather.
The Horizon IT System
13. I had no personal experience or knowledge of the Horizon IT System
prior to my role with the Scheme. To the best of my recollection,
Belinda Crowe made me aware of the fact that SPMs had raised
concerns about possible bugs or defects with the system, as well as a
lack of integrity in relation to how it functioned.
14.Even when I worked on the Scheme, I had no direct involvement with
the Horizon IT system and never received any training on it, nor did I
expect to be, given the nature of the role that I was taken on to
complete.
15.So far as I was concerned the Scheme had been established as part of
the POL commitment to investigate and resolve SPMs'’ claims and as
such I was under the impression throughout that concerns about bugs,
defects and integrity were investigated and resolved by the POL,
working in conjunction with Fujitsu.
16.My understanding in this regard was informed by responses such as
those evident in the email from Belinda Crowe to Mark Underwood and
myself dated 20 October 2014 (POL00211158) and the email chain
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between Angela van den Bogerd, Andy Holt, and me, dated 1 May
2014 (POL00367583).
17.1 also do not recall being made aware of any major issues having been
identified as part of the Second Sight interim report but again, I would
like to stress that my role was very much intended to deal with
information security training and processes for the Scheme and not the
ins and outs of the Horizon IT System and the issues raised by the
SPMs or anyone else.
18.At the time of working on the Scheme, I was unaware of the POL
having a prosecutorial function.
19.So far as my understanding of the ability for Fujitsu employees to alter
transactions or data in branch accounts without the knowledge or
consent of SPMs, this would have been based purely on the
information provided in emails such as those referenced above
(POL00211158 and POL00367583) in which reassurances were
provided as to how the system access worked in order to maintain the
integrity.
20.1 have been provided with a copy of a May 2009 Computer Weekly
article (POL00041564). Having seen this, I do recall reading it when I
started my contract back in 2013; I believe that Belinda Crowe may
have suggested that I read it to understand the background and need
for the Scheme, particularly from the perspective of the SPMs.
21.Apart from that I have no recollection of discussing the article with
anyone during my time working on the Scheme.
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22.1 have no knowledge of the term ARQ data and no specific knowledge
of remote access beyond that which I have alluded to at paragraph 19
above in relation to the reassurances provided by Fujitsu in relation to
system access.
The Initial Complaint Review and Mediation Scheme (“the Scheme”)
23.1 was a part-time contractor throughout my time working on the
Scheme from December 2013 to June 2015.
24.When I started, I think there were five people working on the Scheme
and this grew to about twelve over time.
25.As previously stated, I was brought on board due to my background in
information security. I was tasked with ensuring any sensitive data
relating to SPMs, including their personal, financial and medical details
remained confidential.
26.1 provided data protection training and process reviews as reflected in
documents including the email I sent on 26 March 2014 to John
Breeden, Nick Beal, Mark Wright and others in relation to “Mediation
Representative Training” (POL00147852) and the Initial Complaint and
Mediation Scheme Workshop presentation (POL00147060).
27.My role extended to include more administrative functions with duties
relating to the structure of the mediation process, proofreading
documents and ensuring that the relevant parties adhered to deadlines.
28.Examples of my administrative function can be seen in the email from
Andrew Parsons dated 31/12/2013 (POL00061066) and my email
dated 02/01/2014 to Shirley Hailstones regarding potential
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improvements to the executive summary and report for South
Warnborough M035 (POL00061070).
29.In terms of developing the structure of the mediation process, I simply
collated the information provided to me by Belinda Crowe and Andrew
Parsons.
30. An example of this can be seen in the email from Belinda to me dated
11/12/2013 with the subject “Network Representatives for Mediation”
(POL00300875).
31.Further examples include an email from Andrew Parsons to me dated
12/12/2013 (POL00300882) and an email from me on the same day to
Belinda Crowe and others, also on the topic of “Network
Representatives for Mediation” (POL00300879).
32.1 drafted process maps based on the information provided as can be
seen from the material available to the Inquiry, including the email from
me to Andrew Parsons and others dated 29/12/2013 re the Mediation
Process Maps (POL00407812), as well as the Stakeholder Mediation
Process Diagram of the same date (POL00407813) and the
Stakeholder Scheme Mediation Map (POL00138162) dated
27/02/2014.
33.My involvement so far as the Scheme’s responses to Second Sight
investigations and/or applications made to the Scheme, included
ensuring the timely progression of such matters with effective
monitoring and follow up with POL around deadlines. This can be seen
in my emails including on 05/09/2014 when I emailed Belinda Crowe
and Andrew Parsons re draft case review report (“CRR”) responses
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(POL00136838); my email of 14/01/2015 to Chris Aujard, Belinda
Crowe and others, also in relation to draft CRR responses
(POL00076785); the email from Angela Van-Den- Bogerd to me and
others dated 05/02/2015 re draft CRR Response/ Settlement Analysis
(POL00221283) and my email of 30/05/2014 to Chris Aujard, Belinda
Crowe and others with the subject “Second Sight case review report:
process for response” (POL00204947).
34.As previously mentioned, I proofread documents to identify errors
and/or potential structural changes to make the documents easier to
follow and understand. This is evidenced, for example, by the email
dated 09/05/2014 from me to David Oliver and others (POL00204063).
I did not, however, make or suggest material changes to documents
such that the intent, meaning or message would change from that
intended by the original author, whoever that may be.
35.1 was also very often a go-between who would relay information
amongst various members of the team, for example, the Scheme
workshop agenda dated 17/12/2013 (POL00147063); the email chain
from Daniel Fawcett to me and others re a draft CRR dated 21/10/2014
(POL00211189) and the email from me to Belinda Crowe and Andrew
Parsons dated 05/09/2014 (POL00136838).
36.Whilst I may have been privy to information which I collated and
distributed to others, I must stress that I had no decision-making
authority and was not involved in strategy discussions or decisions
around the disclosure of documentation.
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37.1 did not brief Paula Vennells or other senior managers within the POL.
It is possible that I may have supported others who were involved in
such briefings, for example by collating information provided by senior
members of the team such as Belinda Crowe and David Oliver. Given
the passage of time, I am unable to recall any particular examples.
38.1 have no specific recollection of ever having heard about allegations
that POL may have had unexplained profits caused by SPMs settling
illusory discrepancies, but I can say for certain that I had absolutely no
involvement with any investigation of POL’s suspense account or any
such allegations.
39. My role was that of a part-time junior contractor; I was not given any
reason to question the accuracy of the information being exchanged
between the parties to the Scheme and I was not aware of anything
which caused me to question the integrity of the Scheme, certainly not
in respect of the discreet tasks that I was involved in.
40.Whilst there may have been some disagreements around scheduling
Working Group meetings, as I was reminded of when I reviewed the
Inquiry document dated 10/04/2014 which referenced the cancellation
of a case conference call (POL00202819), I do not recall any specific
tensions and I am unable to comment any further on the day to day
working relationships between any particular individuals or groups.
4
. There were indications of what are perhaps best termed as mis-aligned
expectations in terms of Second Sight’s role and the accuracy of their
reports as seen in my email to Belinda Crowe on 21/05/2013
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(POL00204776) and the email dated 30/12/2013 between Andrew
Parsons, Angela Van- Den-Bogerd and others (POL00199179).
42. However, even if such issues did exist, they were not directly related to
the tasks that I was engaged to complete which as I have said had
become largely administrative and procedural as time went on.
Termination of the Scheme and engagement of Second Sight
43.So far as I can recall, I was tasked with drafting the email I sent to Tom
Wechsler and others dated 16 March 2015 (POL00151646). This was
based on information provided to me by senior members of the
Scheme team including Belinda Crowe, Tom Wechsler and Patrick
Bourke.
44.As stated, my role evolved from cybersecurity consultant to
proofreader, administrator and general go-between. It did not, however,
ever extend to influencer or decision maker and as such I had no
influence or involvement in closing the Scheme or terminating Second
Sight’s engagement.
Working with POL
45.Whilst I may have been involved in proofreading documents and
distributing information between different parties ahead of meetings
and deadlines, I did not have any strategic role in meeting with or
preparing briefs for meetings with Second Sight, MPs or SPMs.
46. The same can be said of my role in relation to communications more
generally; I held a very junior role and my focus was on completing the
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tasks assigned to me. I had no meaningful influence or authority in
respect of the policies or communications coming out of the Scheme.
47.1 have reflected extensively on my role with POL and in particular the
Scheme; the nature of my job was such that there isn’t anything that I
would have done differently.
48.Whilst I am, of course, aware of and supportive of the important work of
the Inquiry into POL and the Horizon IT System, I genuinely cannot
think of anything that I could have done or said which would have
changed how the SPMs were dealt with.
49. I have done my best to address all the issues raised in the Inquiry’s
Rule 9 Request and the contents of this statement are true to the best
of my knowledge and recollection.
Statement of Truth
I believe the content of this statement to be true.
Dated:_25 November 2024
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JESSICA BARKER RULE 9- INDEX TO WITNESS STATEMENT
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No.
URN
Document
Date
Document
Description
Control Number
POL00211158
20/10/2014
Email from
Belinda Crowe
To: Mark
Underwood,
Jessica Barker
CC: Belinda
Crowe re FW:
Strictly Private &
Confidential -
Subject to
Privilege arising
from M008 -
Rivenhall
POL-BSFF-0049221
POL00367583
01/05/2014
Email from
Angela Van-Den-
Boger to Andy
Holt, Jessica
Barker re:
URGENT
ACTION
PLEASE
POL-0185714
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POL00041564
MAY 2009
May 2009
Computer
Weekly article
POL-0038046
POL00147852
26/03/2014
Email from
Jessica Barker to
John Breeden,
Nick Beal, Mark
S Wright & others
- RE: Mediation
Representative
Training
POL-BSFF-0006975
POL00147060
17/12/2013
Initial Complaint
and Mediation
Scheme
Workshop
POL-BSFF-0006185
POL00061066
31/12/2013
Email from
Andrew Parsons
to Shirley
Hailstones to
Angela Van-Den-
Bogerd, Rodric
Williams and
others re South
Warnborough
M035
POL-0057545
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POL00061070
02/01/2014
Email
correspondence
from Jessica
Barker to Shirley
Hailstones re:
improvements to
exec summary &
report - South
Warnborough
M035 (Jo
Hamilton's case)
POL-0057549
POL00300875
11/12/2013
Email from
Belinda Crowe to
Jessica Barker cc
Nicky Mal, David
Oliver and others
RE: Fwd:
Network
Representatives
for Mediation
POL-BSFF-0138925
POL00300882
12/12/2013
Email from
Andrew Parsons
to Jessica Barker
RE: Network
POL-BSFF-0138932
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Representatives
for Mediation.
10
POL00300879
12/12/2013
Email from
Jessica Barker to
Belinda Crowe cc
Nicky Mal, David
Oliver and others
RE: Network
Representatives
for Mediation
POL-BSFF-0138929
11
POL00407812
29/12/2013
Email from
Jessica Barker to
Andrew Parsons,
Rodric Williams,
Chris Aujard and
others re:
Mediation
process maps
POL-BSFF-0232779
12
POL00407813
29/12/2013
Stakeholder
mediation
process diagram
POL-BSFF-0232780
13
POL00138162
27/02/2014
Stakeholder
Scheme
Mediation Map.
POL-BSFF-0000391
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14
POL00136838
05/09/2014
Email from
Jessica Barker to
Belinda Crowe
and Andrew
Parsons re:
M029 and M039
draft CRR
responses
POL-0125392
15
POL00076785
14/01/2015
Email from
Jessica Barker to
Chris Aujard,
Belinda Crowe,
Rodric Williams,
and others re:
Draft CRRs:
MOS56, M064,
M101, M105,
M109, and M119
- Mediation
Scheme
POL-0073348
16
POL00221283
05/02/2015
Email from
Angela Van-Den-
Bogerd to
Jessica Barker
and others. CC
POL-BSFF-0059346
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ing Patrick
Bourke, Belinda
Crowe and
others. RE: M075
- draft CRR
Response /
Settlement
Analysis [BD-
4A.FID26231777]
17
POL00204947
30/05/2014
Email from
Jessica Barker to
Chris Aujard,
Belinda Crowe,
Angela Van-Den-
Bogerd and
others RE:
Second Sight
case review
report: process
for response
POL-BSFF-0043010
18
POL00204063
09/05/2014
Email from
Jessica Barker to
David Oliver and
others re Letter
to SS - M022.doc
POL-BSFF-0042126
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19
POL00147063
17/12/2013
Post Office Initial
Review and
Mediation
Scheme
workshop
agenda.
POL-BSFF-0006188
20
POL00211189
21/10/2014
Email chain from
Daniel Fawcett to
Jessica Barker,
Chris Aujard,
Belinda Crowe
and others re
M078 draft CRR.
POL-BSFF-0049252
21
POL00202819
10/04/2014
Matrix, Post
Office, JFSA,
Linnell & Co and
Advanced
Forensics emails
re working group
case conference
call cancellation.
POL-BSFF-0040882
22
POL00204776
21/05/2013
Email from
Jessica Barker to
Belinda Crowe re
M022
POL-BSFF-0042839
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23
POL00199179
30/12/2013
Email chain
between Andrew
Parsons, Angela
Van-Den-Bogerd,
Belinda Crowe
and others re:
mediation
POL-BSFF-0037242
24
POL00151646
16/03/2015
Email chain from
Jessica Barker to
Tom Wechsler,
Belinda Crowe
and others re
draft note for
Reps
POL-BSFF-0010758
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