WITN09130100 Davlyn Cumberland - Witness Statement

Evidence on official site

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Witness Name: Davlyn Cumberland
Statement No.: WITN09130100

Dated: 6.6.2023

POST OFFICE HORIZON IT INQUIRY

FIRST WITNESS STATEMENT OF DAVLYN CUMBERLAND

I, Davlyn Cumberland, will say as follows:

Introduction

1. 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 24 April 2023 (the
“Request”). I have received advice and assistance from a lawyer in the

preparation of this statement.

My professional background

2. I am an employee of Post Office Ltd (“POL”) and have worked in a number of
roles since 1990. The dates I have given in the account below are accurate to the

best of my recollection.

3. lL originally started working for POL in August 1990 as a counter clerk. During the

first few years I worked in a variety of main Post Office branches in Wokingham,

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Bracknell, Camberley, Reading and Salford City.

I had a 6-month break in 1993 and returned as a casual worker at Camberley
Post Office in 1994. That role became permanent. After a few months I
transferred to Reading Post Office and then went on to work as an on-site trainer

for a period of 18 months before returning to work in Reading Post Office in 1996.

In 1999 I moved north and worked for a brief period at Salford City Post Office
before joining the Horizon Implementation Programme in September 1999 as a

Horizon Field Support Officer.

In 2001 I joined a programme called the Retail Line Review Trial and worked in
an admin/support advisors’ role. Two new teams evolved from this, the
Performance Improvement Team and the Suspense Account Team. I spent

several months working in both teams.

In 2004 I joined the Network Reinvention Project in an admin support role, which
involved approving processing grant applications from independent sub-

postmasters.

In 2005 I was promoted to the role of Area Intervention Manager, providing on-
site support and guidance to Post Office branch staff, sub-postmasters and

managers.

In 2006 I was promoted again to the role of Contact Issues Manager. In that role
I managed the administrative support team who supported the contract managers
nationally. The team were required to send letters, acknowledge resignations,
arrange completion of vacancy reports, book interviews, answer queries or

escalate queries to the relevant contract manager. This was a new role which

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evolved over a period of two years. I became involved with implementing new
processes such as the process of appointing temporary postmasters. I worked in

this role until 2008.

10. I took a further career break, this time for four years, before re-joining POL in
2012 to work on the Network Transformation Programme as a Field Change

Advisor.

11. In 2013 I joined the On-site Training Team where I have worked to this day, apart
from a period from August 2022 to April 2023 when I was on temporary

secondment to the Training Scheduling Team.

My role in the Suspense Account Team

12. I have been asked to describe in particular my role in the Suspense Account
Team, and I have set out an account of this here as I remember it to the best of

my knowledge.

13. As I mentioned above, from 2001 until 2004 I worked in a team that was initially
called the Retail Line Review Trial. The Retail Line Review, as far as I can recall,
involved centralising the support from the regional helplines to the new Network
Business Support Centre and closing the regional area offices (with the exception

of the area offices which served the rural network).

14. The Retail Line Review split the Post Office branch network into two categories:
Community (Rural) and Commercial. The Rural network was supported by area

offices and the Commercial network was supported by Retail Line Managers.

15. Two new centralised teams were also formed and were initially based at the

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Network Business Support Centre in Barnsley. These two teams were called the
Suspense Account Team and the Performance Improvement Team. I worked in

both teams.

My role in the Suspense Account Team was to contact Post Office branches by
telephone to discuss and, if necessary, raise queries about unauthorised
discrepancies (representing unaccounted for losses and gains) held in the
suspense account, using the data supplied to my line manager every month from
a team based in Chesterfield. My line manager would then distribute the workload

throughout the team.

In addition, I was required to contact Post Office branches by telephone whenever
a call had been escalated to our team by an advisor in the Network Business
Support Centre, which was the first point of contact for sub-postmasters,
managers or branch staff seeking authorisation to hold a discrepancy in the
suspense account for a limited period. My role was to authorise the discrepancy
to be placed into the suspense account, if the discrepancy was a result of a known
accounting error. When the discrepancy wasn't authorised, I would offer guidance
to help locate the cause of the accounting error/discrepancy; for example, to
check documentation dispatched to savings bank and Giro bank, cheques sent
for processing, cash and stock remittances in and out of the branch, automated
payments (bills), currency and travellers cheques had been entered correctly,
and that pensions and allowances paid to customers agreed with dockets on
hand. Key stroke mistakes were sometimes the cause of discrepancies, for

example someone entering £800 rather than £80.

These calls could be quite stressful and uncomfortable on occasions, because

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not all discrepancies would get authorised, and people would sometimes become
upset. After a period of approximately 6 months, I wasn’t really enjoying the job,
mainly due to the nature of the work and because I didn't find it rewarding or
interesting, so I asked to transfer to the Performance Improvement Team which
had then been relocated from the Network Business Support centre in Barnsley

to Chesterfield.

My role as an advisor in the Performance Improvement Team involved contacting
Post Office branches by telephone to discuss accounting and data input errors,
based on monthly data supplied by a team in Chesterfield to my line manager.
My line manager would then distribute the workload throughout the team. These
were non-financial data input errors which would not cause the branch account

to have any discrepancies.

My role was to offer support and guidance to rectify errors and talk people through
correct procedures. The aim was to help the branch staff understand correct
procedures so that, going forward, they could implement changes to improve

performance in relation to reporting of transactions.

I spent approximately six to nine months working in the Performance
Improvement Team, but it became difficult to continue because the travelling
commitments were excessive. Eventually I asked to return to the Suspense

Account Team because less travelling was involved.

I have been asked to describe the role of the Suspense Account Team. It has
been a long time since I worked in the Suspense Account Team, but I have tried

to describe its role to the best of my recollection.

The role of the Suspense Account Team was to monitor and manage

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discrepancies being held in the suspense account across the Post Office branch
network. The objective was to reduce the number of discrepancies held in

individual Post Office branch suspense accounts.

If a discrepancy showing in the suspense account was due to a known
transactional error, with an expected correction to be issued by the relevant team
in Chesterfield and where proof such as documentation was supplied (for
example, a cash in payment had been written as a withdrawal, or if the error was
verified by the relevant team — such as the savings bank, cheque processing,
Giro bank, cash centre, or automated payments teams) the discrepancy would
be authorised and it could be held in the suspense account up to eight weeks
until the correction had been issued. A reference number for the authorisation

would be provided.

If the discrepancy was not due to a known transactional error, then we would
discuss this with the Post Office branch manager/sub-postmaster, explain that it
wasn't an authorised discrepancy, and request that the discrepancy be removed
from the suspense account before the next cash account due date. Any loss had
to be made good either by cheque or cash, and any gain corrected by a

withdrawal of cash.

If a branch had any difficulty with this process or said that they were not able to
make good the amount, we would the escalate the case to the relevant area
manager for Rural branches or the Retail Line Manager for Commercial

branches.

In some cases, a hardship application would be submitted. If this was agreed, a

discrepancy could be made good by making deductions from monthly

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remuneration.

28. Another part of the Suspense Account Team's role was to telephone Post Office
branches when a Network Business Support Centre advisor escalated a call to
our team. This usually happened when a branch sought authorisation to hold a
discrepancy in the suspense account due to a known error. Our role was to assist
and support the branch to locate the error. Sometimes the error would get
resolved during the call, sometimes the branch would call back to say they had

found the discrepancy.

Early Involvement in relation to Marine Drive Post Office

29. I have been asked to explain my recollection of my involvement in the Marine
Drive Post Office, where Lee Castleton was the sub-postmaster. My attention has
been drawn to some documents, including the note of decision to terminate Mr
Castleton's contract on 10 May 2004 (POL00070758) and a witness statement I
made in a civil case involving POL and Mr Castleton dated 2 October 2006

(LCAS0000566).

30. The events described in these documents took place a very long time ago, and
I'm sorry to say that I have no recollection of them or of any involvement I had in

them. I cannot recall making the witness statement at LCAS0000566.

31. The note at POL00070758 says that I and my colleague Elizabeth (Liz) Morgan
helped to explain some discrepancies in the final balance figures, and I note that
I said in my witness statement at LCAS0000566 (at paragraph 3) that I was asked
by Liz to examine some branch accounts she had been sent by Catherine

Oglesby, Mr Castleton's Retail Line Manager. I have some recollection of Liz

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Morgan asking me to look at some branch paperwork to see if I could spot any
errors or abnormalities, but I can’t remember anything about which Post Office

branch this related to or what the outcome was.

Liz Morgan and I worked together in the Suspense Account Team. We were a
small close-knit team, and it was usual practice to ask for assistance from
colleagues. Although checking branch accounts was not officially part of our role,
I can recall a few occasions when a Retail Line Manager or Area Manager would
ask for our help with checking branch weekly accounts and possibly the
transaction logs. I recall that Liz was well known within POL, especially in the
north, because she worked in the audit team for many years. It wasn’t unusual
for her to offer to check branch accounts although, as I said, it wasn’t officially

part of our role. I cannot recall how many occasions she asked for my help.

During my Post Office career, I have gained knowledge and experience by
supporting sub-postmasters and their staff with back-office duties and weekly
balancing. Looking back to the time when the events described in POL00070758
and LCAS0000566 took place, I believe I would have had a good understanding
of the Post Office branch weekly accounting system. This was gained from
working as an on-site trainer between 1994 and 1996, using both the old manual
accounting system and an electronic system (Eccot+) used at the time in our
Crown branches, and working on the Horizon Implementation Team as a Field
Support Officer, a job which involved the migration of manual data onto the new
Horizon system then staying on-site to offer support including completion of the

first weekly balance.

I am unable to recall carrying out the task of looking at the accounts for the Marine

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Drive branch, of any steps that I took or of any documents that I was provided.
The note at POL00070758 suggests that Liz Morgan and I came to a view about
the figures in the accounts and whether there was anything wrong with the
Horizon system, and I said in my witness statement at LCASO000566 that we
were unable to find anything unusual or evidence that the losses were not
genuine, but I am afraid that I cannot recall anything about how I came to that

view. I don't recall having any discussions with Catherine Oglesby.

I have no recollection of any other Post Office branches reporting discrepancies

caused by the Horizon system at this time.

I have been asked if Liz Morgan or I considered requesting further information
from Fujitsu. As I say, I cannot recall any specific details of the Marine Drive case,
but I am satisfied that we would not have had the authority to involve any other
teams such as Fujitsu as this would be a matter for the investigation teams. As I
said before, the checking of branch accounts was not officially part of our role
This was done on a few occasions as a favour to help out Retail Line Managers

and Area Managers.

I have been asked to explain my understanding of Mr Castleton's personal
financial situation at this time and who was responsible for decisions about
hardship applications. Again, I cannot recall any specific details of this case.
Decisions on hardship applications were not part of my role, so I think it unlikely
I would have had any conversations about Mr Castleton's personal financial
situation. Decisions regarding hardship applications were usually from the Retail

Line Manger or Area Manager.

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38. I cannot recall having any involvement with Mr Castleton's case or the Marine

Drive Post Office prior to the civil litigation referred to in the Request.

Post Office Limited v Lee Castleton

39. Ihave already referred to the witness statement I made in 2006 at LCASO000566
and that I cannot recall these events or making the statement. Neither can I recall

being involved in any other legal proceedings involving the Horizon system.

40. My attention has been drawn to an email that Stephen Dilley, a solicitor at Bond
Pearce LLP, sent to Liz Morgan and I on 22 August 2006 (POL00071073). The
email describes legal action POL was taking to recover losses accrued while Mr
Castleton was sub-postmaster at the Marine Drive Post Office. It appears to be
the case that Mr Dilley asked me to provide a witness statement, and that I did
so, but I am afraid I have no recollection of being asked to make a statement or

of making the statement.

41. There is also a note of a telephone call I had with Mr Dilley on 2 October 2006
about a witness statement I had prepared and the process for approving it
(POL00072707). I cannot recall the details of this conversation, or of any other
conversations with any other lawyers representing POL. I have no recollection of
being told about, or being given any details about Mr Castleton's defence or
counterclaim, or of having any involvement in the disclosure process during these

proceedings.

42. Iam afraid I cannot offer any observations about this legal case since I genuinely

cannot recall anything about it or what part I played in it.

Other Civil and Criminal Cases

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43. I have been asked about my recollection of a number of other individuals who
were the subject of criminal and civil proceedings, but none of the names are

familiar to me and I have no recollection of any cases involving them.

44. To my knowledge I haven't been involved in any investigations or criminal
prosecutions to do with the Horizon system, nor have I been involved in any civil

cases (apart from providing a witness statement in Mr Castleton's case in 2006).

Knowledge of Bugs, Errors and Defects in the Horizon System

45. Iam asked to describe whether I had, or was aware of, any concerns about the
robustness of the Horizon system during my time at POL. During my time working
for POL, I have not been aware of or witnessed any bugs, errors or defects in the
Horizon system whilst performing my daily duties. Working with the Horizon

system has never given me any cause for concern.

46. I did become aware of some sub-postmasters taking legal action against POL
and that they had claimed that faults in the Horizon system had resulted in
accounting discrepancies. I cannot remember exactly when this was, but think it
must have been after I started working for POL again in 2012. Nor do I recall how
exactly this was brought to my attention. I recall that senior management at the
time provided us with a standard response (although I don't recall the specific
wording) to any questions raised by branch staff while we were outperforming our
daily roles. To my knowledge, the first time POL acknowledged there could be a
problem with the Horizon system was during the group litigation case. I think this

was at some point in 2019 but can't be certain of the exact date.

Other Matters

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47. There are no other matters I wish to bring to the attention of the Chair of the

Inquiry.

Statement of Truth

I believe the content of this statement to be true.

Signed:

Davlyn Cumberland (Jun 6, 2023, 8:29am)

06 Jun 2023
Dated:

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Index to First Witness Statement of Daviyn Cumberland

No. I URN Document Description

1. POL00070758 INote of decision to terminate Lee
Castleton's contract, 10.5.2004

2. LCAS0000566 _ I Witness Statement of Davlyn Cumberland
made in Post Office Ltd v Castleton case,
2.10.06

3. POL00071073 I Email from Stephen Dilley, Bond Pearce
LLP, 22.8.2006

4. POL00072707 I Telephone attendance note taken

Stephen Dilley, Bond Pearce LLP,
2.10.2006

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