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Witness Name: Dennis Watson
Statement No.: WITN08430100.
Dated: 09 October 2023
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF DENNIS WATSON
I, Dennis Edward Watson, will say as follows ...
Introduction
1. I am a former employee of Post Office Ltd and held the position of Network
Field Support Advisor.
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 22 August
2023 (the “Request”).
Background
3. I have been asked to set out a brief outline of my role in Post Office Counters
Ltd (POCL). In respect of this I would like to point out that I retired from the
Post Office on 19" March 2011 and with the passage of time my recollection of
times and dates is very limited as I have no records of my own to refer to.
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4.
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I can confirm that I began work, with no qualifications, at the General post
Office (GPO) on 24" September 1979.
I worked as a postman for two years and then as a PHG (postman higher
grade) for possibly a couple of years. I then decided to transfer to the counters
side of the business and having passed a written test moved onto the counters
side of the business as a counter clerk at Bank Street Post Office in Bradford.
There I was trained in the many and various transactions by experienced
counter clerks. Having worked there for quite a few years I applied to join the
Regional Helpline. Having passed the interview I went to work on the Regional
Helpline which was based in City Square Leeds. The job there entailed
answering queries from Post Office staff and also the general public. After a
few years on the Helpline I heard Training were looking for new trainers so I
applied and was interviewed and with all the knowledge I had gained in my
previous positions I was accepted.
Having worked as a trainer for quite a while it was decided to amalgamate the
Training Team with the Audit Team and I think that was when my title changed
to Network Field Support Advisor. Trainers then shadowed auditors to learn
about auditing and vise versa until both teams were trained in all aspects and
became one team. I understood that the role would involve both training and
audit work in all offices (branch offices and sub post offices) from that time.
My role, from this time on, was to train subpostmasters and counter clerks and
audit offices as and when instructed to do in subpostoffices, Branch Offices
and Cash Centres.
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8. Everyone was placed in small teams of approximately six people with each
team having a line manager. In respect of line management I reported to my
team line manager which changed from time to time. At the time of my
retirement my line manager was Peter Jackson.
9. Inall the teams I worked in I found all my colleagues to be highly competent
and professional when carrying out their roles, whether it be auditing or
training, at all times.
10.1 had no role in disciplinary matters or interviewing those accused of a criminal
offence. I made no disclosures and was not involved with litigation or liaison
with other departments.
11.1 have no record of the number of audits that I attended or led. I did more
training than audits. The records on this would possibly be held by the
Scheduling team, that was the team that allocated all the work to our teams. At
the time of my retirement the Scheduling team was based in Salford.
Th it pr nd thi lici racti in pl
12.In respect of the audit process, my role was mainly to assist the lead auditor or
audit manager in case of Branch Offices or Cash Centres. I can’t explain any
changes to policies/practices as I don’t remember any that there may have
been.
13.1 have been asked about the recruitment and training of auditors, and I have
considered the following documents: POL000332698, POL00086765,
POL00088453 and POL00088557. I may have but I do not remember having
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seen them before and one of them (POL00086765) is dated 2013 and I retired
in 2011.
14.1 have no knowledge of how auditors were recruited, I can only say that in my
case it came about when Training and Audits were merged into one team.
15. There may have been a minimal level of qualification and/or experience an
individual was expected to have before conducting an audit. I would imagine
that this would be determined by the individual's line manager.
16.My audit training was through shadowing experienced auditors until I was
considered competent. As for refresher training I would think that would take
place as and when deemed necessary.
17.1 felt that auditors had the necessary experience and training.
18.1 have been asked about the planning and scheduling of audits. Having
considered POL00084650 I have no knowledge of the scheduling or planning
of audits, and I was not aware of any inquiries or investigation conducted
before a branch visit.
19.1 don’t know how frequently branches were audited or any variation between
Crown Offices and other branches.
20.1 have been asked about the auditing process and I have considered the
following documents: POL00083966, POL00084801, POL00085534
(May2011), POL00087627 (May2015), POL00088252 (Aug 2016),
POL00087672 (Apr 2015), POL00084003, POL00084813, POL00085652 (Oct
2011), POL00086765 (2013), POL00087688 (Sep 2015), POL00087716 (Nov
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2014) and POL00087614 (Apr 2015). I am not aware of having seen some of
these as they were produced after I retired and I am not sure if there were earlier
versions.
21.1 have been asked what sources of information I would consider when
completing an audit, and whether the sources varied according to the type of
audit being conducted. I don’t fully understand the question as I only
remember doing one type and that was subpostoffices.
22.When a discrepancy was discovered during an audit I would carry on until I
was satisfied that all cash and stock had been accounted for.
23.1 was not aware of any practice where auditors asked subpostmasters to make
good discrepancies on the day of audit.
24.1 was not aware of any auditors being given any instructions on taking payment
from subpostmasters.
25. If a discrepancy or shortfall was discovered I believe subpostmasters would be
able/allowed to provide their own information and undertake their own
investigation. I have no experience of this ever happening.
26. The information communicated to a subpostmaster during an audit was just a
matter of keeping them up to date on how much we had done and what was
still to be done.
27.1 don't know of any instances where a subpostmaster raised an issue/concern
during an audit so I am not sure how it would be dealt with. I suppose it
depend on what the particular issue/concern was.
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28.1 have been asked if it was possible to conduct a branch audit in
circumstances where it was not possible to access the Horizon IT system. I
cannot see how it would be possible to perform an audit without full access to
the Horizon system.
29.1 have been asked to describe any variation between the audit process in
respect of Crown Office branches and other branches. CrownOffices have
multiple individual stock units and each one has to be checked separately
therefore more auditors attend a Crown Office audit. In principle it is the same
procedure as auditing a subpostoffice, just on a larger scale.
30.1 have been asked to consider documentFUJ00001894 - Audit Trail Functional
Specification (version 8.0, 18 October 2004). I don’t think that I have ever seen
this document before and don't see how it might help in my role as an auditor.
31.1 have also been asked to consider documentPOL00002841 - Global User
Account (September 2016). This is an account that can be obtained to allow an
auditor access to the Horizon system in an office where no one with manager
access to the system is available, thus enabling the auditor to perform an audit.
32.1 have no knowledge of any involvement Fujitsu might have in the audit
process.
33.1 have been asked whether auditors had access to information to which a
subpostmaster did not have access when they were conducting a branch
audit. I can’t think of any information auditors might have access to that the
subpostmaster didn’t have access to.
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34.1 have never had to use an Audit Global User Account, and I don't know what
audit measures might be in place.
Prosecution of Mr Khayyam Ishaq
35.1 understand that the Inquiry is seeking a full and detailed account of the
prosecution of Mr Khayyam Ishaq and I will to my best to assist, but as
mentioned previously that with the passage of time my recollection of any
times, dates or conversations will be very limited.
36.1 have been asked to consider Having-viewedthe-documents POL00056076,
POL00057696, POL00066747, POL00066741, POL00066740 and
POL00057078. I would like to say that with regard to POL00057696 this witness
statement is dated 8" May 2012 and as mentioned previously I retired from the
Post Office on 19" March 2011. Also, the 2” and 3” pages are headed David
Watson.
37. According to document POL00046324 I would have first met Mr Ishaq on 4”
July 2008 to commence his onsite training.
38.1 have been asked to describe the circumstances in which the audit of &
February 2011 was scheduled, and the process by which the audit was
conducted. The audit of 8 Feb 2011 was initially a cash check which was
probably scheduled in that a request would have gone to the Scheduling team
they would then allocate it to an available auditor. Only after performing the
cash check and finding a discrepancy did it turn in to a full audit.
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39.The process for conducting the audit at Birkenshaw Post Office would be as
described in document POL00056076.
40.1 have been referred to the witness statements of Kathleen Smith at
POL00057701 and POL00060082 and asked to describe our respective roles.
Myself and Kathleen Smith worked together to perform the audit and our roles
were exactly the same in that we checked all the cash and stock in the office to
enable to see if there were any discrepancy. The only difference in my role was
that I would write any reports required at the end of the audit.
41.1 am unable to provide any details of any discussions that I may have hadwith
Mr Ishaq apart from what is mentioned in POL00056076. I have no memory of
anything else it was too long ago.
42.1 have been asked to provide details of any documentation I considered during
the audit, and I have been referred to the witness statements of Stephen
Bradshaw at POL00057582 and POL00059887, together with the exhibits at
POL00105185 p37 - 48. The documentation that I would considerduring the
audit would be my own audit sheet(s), Balance snapshots, Stock on hand
report and Trading statements.
43.1 have been asked to consider documents POL00105185 p37-48,
POL00107884, POL00060081 and POL00046325. My initial enquiries revealed a
shortage in the cash because my original purpose for visiting the office was to
perform a check of the cash on hand at the office. Only then after informing the
Contracts manager that there was a discrepancy in the cash was I asked to
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perform a full audit of the cash and stock held at the office. It was then that it
revealed that some of the of stock figures had been inflated.
44.1 have been asked if the size of the discovered shortfall was unusual and
whether I had any concerns about it. I don’t know whether I thought it unusual
or not and I don’t remember having concerns about it.
45.1 have been asked to describe any further investigation I undertook to
ascertain the cause of the shortfall. I cannot think of any further investigation
that may have taken place.
46.1 have been asked if ARQ logs were sought by POL from Fujitsu in this case,
and if not why not. I am not aware of ARQ logs and I think it would be for
someone else to answer that question.
47.I have been asked to provide details of any discussions I had with Stephen
Bradshaw, the lead investigator in this case, or with other investigators. I don’t
remember ever having any discussion with Stephen Bradshaw or any other
investigator before, during or after the audit.
48.1 have been asked to provide details of the documentation I completed after
the audit. Documentation completed after the auditwould be the audit report
and the result of the audit was reported to Andy Carpenter.
49. The decision to suspend Mr Ishaq was taken by Andy Carpenter.
50.1 had no further involvement in the case of Mr Ishaq prior to the decision being
made to charge him.
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51.1 am not aware of any other audits taking place at Birkenshaw Post Office prior
to 8" February 2011.
52. With regard to witness statement WITN01700100, in paragraph 16 he Mr
Ishaq states that he only received 3 days training in Leeds prior to taking over
Birkenshaw Post Office, but in the training report POL00046324 it shows he
had 10 days in the classroom. Paragraph 17 states that his onsite training
consisted of back-office balances and sales, yet in another statement I seem
to remember he states that he didn't receive any back-office training. As he
states that he was having issues with the Horizon he could have requested
extra training or at least been offered it.
53.1 have not been involved in any other proceedings against SPMs, their
managers, assistants or Post Office employees involving shortfalls shown by
the Horizon IT system before this case.
54.1 don’t remember ever being asked to give a witness statement in the case
against Mr Ishaq. I don’t remember having contact or discussions with anyone
regarding drafting a witness statement.
55.1 have been asked for my view of how the prosecution was conducted by POL.
Until now I wasn’t aware of how the prosecution was conducted by POL
therefore I didn’t have a view. I was never informed of the outcome of the case
against Mr Ishaq.
56. Reflecting on the investigation done in the case of Mr Ishaq, I feel that he was
treated badly and not enough attention was given to his claim that there were
problems with the Horizon system at his office.
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57.I have been asked about the extent to which, if any, I consider a challenge to
Horizon in one case to be relevant to other ongoing or future cases. A
challenge to the integrity of Horizon in one case has to be relevant to ongoing
and future cases, because if proven that there is problem with the system this
must be taken into consideration in all other cases.
58.1 have been asked if I consider the investigation into bugs, errors and defects
in Horizon was sufficiently carried out by the Post Office. I have no way of
knowing what if any investigations were carried out.
59.1 have been asked if I consider sufficient information regarding bugs, errors
and defects in Horizon was passed to the Post Office by Fujitsu. I have no
knowledge of what if any information was given to the Post Office by Fujitsu.
60.1 have been asked if I consider I had sufficient information regarding bugs,
errors and defects in Horizon. I was never given any information regarding
bugs, errors and defects in Horizon. If such information was available it should
have come from Management. I would state that we were always told that if
questioned on the integrity of Horizon the Post Office position was that
Horizon was a very robust system.
61.1 have found this statement very difficult to complete. With the passage of time
it hasn't been easy trying to remember dates, times and processes. Some of
the documents provided have helped to remind me because as I stated before
I have no records of my own.
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Statement of Truth
I believe the content of this statement to be true.
Signed:-
Dated:- 09 October 2023
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Index to First Witness Statement of Dennis Edward Watson
No. I URN Document Description Control No.
1 POL00032698 I Assurance Review - Recruitment (Vetting & POL-0029633
Training) (27 October 2009)
2 POL00086765 I Network auditing approach, methods and POL-0083823
assurance
3 POL00088453 I POL's advert for training and audit advisor role I POL-0085511
(undated)
4 POL00088557 I POL job poster for audit advisor role within loss I POL-0085615
prevention team (undated)
5 POL00084650 I Chapter 1 of Audit Process Manual — Audit POL-0081708
Plan & Scheduling
6 POL00083966 I Audit Charter: Branch and Cash Centre Audit / POL-0081024
Activity — undated. This policy document sets
out the standards and code of ethics that apply
to those staff performing audits of branches
and cash centres within Post Office Ltd.
7 POL00084801_ I Audit Process Manual: Chapter 3 - Performing I POL-0081859
a Branch Audit (v5.1)
8 POL00085534 I Audit Process Manual: Chapter 3a - Core & POL-0082592
Outreach Audit Process (v1.0)
9 POL00087627 I Audit Process Manual POL-0084685
10 I POL00088252 I Audit Process Manual Volume 4 - Chapter 7 POL-0085310
Performing a cash centre audit
11 I POL00087672 I Audit Process Manual Volume 4: Chapter 11 - I POL-0084730
Quality Assurance V5.0
12 I POL00084003 I Audit Process Manual for compliance team POL-0081061
process for auditing branches without access
to horizon
13 I POL00084813 I Condensed Guide For Audit Attendance POL-0081871
14 I POL00085652 I Requirement of Network Field Support POL-0082710
Advisors at audit, following discovery of
discrepancy
15 I POL00087688 I Training Guide - Compliance audit tool v 6.1 POL-0084746
16 I POL00087716 I Training-Aide for Branch Asset Checking (v1.7) I POL-0084774
17 I POLO0087614 I Terms of Reference Audits POL-0084672
18 I FUJ00001894 I Fujitsu Services Audit Trail Function POINQ0008065F
Specification (v8.0)
19 I POL00002841 I Global User Accounts Guidance for Sandra VIS00003855
McBride
20 I POLO0056076 I Memo/ Report from Dennis Watson to Paul POL-0052555
Williams, Re: Audit of Post Office Birkenshaw
Branch Code 163306
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21 IPOL00057696 I Witness Statement of Dennis Watson - POL-0054175
Khayyam Ishaq
22 I POL00066747 I Note of Interview of Steven Bradshaw POL-0063226
23 I POLO00066741 I Transcript of Khayyam Ishaq interview. Tape 2 I POL-0063220
of 2
24 IPOLO00066740 I Khayyam Ishaq case study: Transcribed Notes I POL-0063219
of Khayyam Ishaq interview - investigation of a
criminal offence
25 IPOLO00057078 I Khayyam Ishaq case study: Investigation POL-0053557
(Legal) report by Stephen Bradshaw re
Khayyam Ishaq
26 I POL00046324 I Summary of achievement of performance POL-0042803
standards - Birkenshaw Post Office
27 IPOL00057701 __I Witness Statement of Kathleen Smith POL-0054180
28 IPOLO0060082 I Khayyam Ishaq Case Study: Witness POL-0056561
Statement of Kathleen Smith
29 IPOL00057582 I Witness Statement of Stephen Bradshaw POL-0054061
dated 2012
30 I POL00059887 I Witness Statement of Stephen Bradshaw POL-0056366
31 I POL00105185 I Compilation of Witness Statements (draft), POL-0080810
Interviews and Branch Audit documents -
Kevin Ince
32 I POL00107884 I Regina v Khayyam Ishaq, Expert Report of POL-0106120
Beverley Ibbotson - Joint Statement of
Beverley Ibbotson & Gareth Jenkins with
manuscript comments from third party.
33 I POL00060081 Khayyam Ishaq Email from Rachael Panter to I POL-0056560
Steve Bradshaw re. Cash on hand - counted
on day of audit
34 I POL00046325 I Summary of achievement of performance POL-0042804
standards
35 I WITNO1700100 I WITN01700100 - Khayyam Ishaq WITNO1700100
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