1 Tuesday, 7 March 2023 2 (10.00 am) 3 MR STEVENS: Good morning, sir, can you see and hear me? 4 SIR WYN WILLIAMS: Yes, I can, thank you. 5 MR STEVENS: Thank you, sir. This morning we will be 6 hearing evidence from Elizabeth Evans-Jones, but earlier 7 today a few further documents were provided for her to 8 consider and I would ask that we could adjourn her 9 evidence by 15 minutes to allow a bit more time for her 10 to consider those documents. 11 SIR WYN WILLIAMS: Yes, of course, Mr Stevens. So we will 12 begin as soon after 10.15 as you think appropriate. 13 MR STEVENS: I'm very grateful. Thank you, sir. 14 SIR WYN WILLIAMS: Right. 15 (10.01 am) 16 (A short break) 17 (10.16 am) 18 MR STEVENS: Sir, can you see and hear me? 19 SIR WYN WILLIAMS: Yes, I can, thank you. 20 MR STEVENS: Thank you for the time. If I may call 21 Ms Evans-Jones. 22 ELIZABETH JANE EVANS-JONES (affirmed) 23 Questioned by MR STEVENS 24 MR STEVENS: Good morning. As you know, my name is Sam 25 Stevens and I ask questions on behalf of the Inquiry. 1 1 Please could you state your full name? 2 A. Elizabeth Jane Evans-Jones. 3 Q. Firstly, thank you for giving evidence to the Inquiry, 4 both in a written statement which we'll turn to today 5 and also for attending to give oral evidence, and 6 considering the additional documents that we gave to you 7 this morning. You, should have a written statement in 8 front of you in the bundle of documents under tab A. Do 9 you have that there? 10 A. I do, yes. 11 Q. It runs to 21 pages. 12 A. It does indeed, yes. 13 Q. On page 16, there should be a final paragraph 43 -- 14 A. Mm-hm. 15 Q. -- and beneath that a statement of truth and your 16 signature. Is that your signature? 17 A. I can confirm it is, yes. 18 Q. Can you confirm that the contents of that statement are 19 true to the best of your knowledge and belief? 20 A. Absolutely, yes. 21 Q. Thank you. That stands as evidence in the Inquiry now 22 and, for the transcript, the reference is WITN06680100. 23 I am going to ask you some more questions about it but 24 not cover everything that's within it. 25 Firstly, by way of background, you graduated in 2 1 1999 -- 2 A. I did. 3 Q. -- and you joined Fujitsu in October 2005 to work on the 4 Post Office Account? 5 A. That's correct, yes. 6 Q. You were a Service Delivery Team manager? 7 A. I was, yes. 8 Q. If you could just move slightly closer to the 9 microphone, it's just -- thank you, I'm very grateful. 10 A. You're welcome. 11 Q. Prior to that role, could you summarise any 12 qualifications that you had that were relevant to 13 carrying out that job? 14 A. So I was ITIL certified Version 3 Expert, so that's the 15 IT Infrastructure Library, which delivers best practice 16 in terms of how to manage and delivery services. 17 Q. What work experience or professional experience had you 18 had in delivering a role like that prior to joining 19 Fujitsu? 20 A. So prior to joining Fujitsu, I worked in Threadneedle 21 Asset Management where I ran the service management 22 department for a period of time; I was also a change 23 release and configuration manager; and previous to that, 24 I worked for Yellow Pages also in ITIL service 25 management functions. 3 1 Q. When the role came up for you to join Fujitsu, do you 2 recall how you were selected for it? 3 A. I was recommended by a colleague who used to work -- 4 I was put forward -- who I used to work with at 5 Threadneedle, he put me forward for the application to 6 Fujitsu. I then went through two or three rounds of 7 interviews with Fujitsu and then I was selected for the 8 role. 9 Q. You stayed in the role on the Post Office Account until 10 December 2007? 11 A. That's correct. 12 Q. Then you moved to a different account but within 13 Fujitsu? 14 A. That's correct, yes. 15 Q. When you were working for that different account, from 16 December 2007 onwards, did you have any more working or 17 dealing with the Post Office Account? 18 A. Not from a work perspective. Obviously I had colleagues 19 that I interacted with but not from a work perspective. 20 Q. So when you finished on the Post Office Account in 21 December 2007, that's your last dealings with the 22 Horizon and the Post Office Account? 23 A. Correct. 24 Q. You left Fujitsu in August 2010? 25 A. December -- err, yes, August 2010, that's correct, yes. 4 1 Q. I want to look at support services generally first. 2 You're primarily going to talk about what was known as 3 either the Horizon System Helpdesk or the Horizon 4 Service Desk? 5 A. Mm-hm. 6 Q. I'm just going to refer to it as the Helpdesk for 7 today -- 8 A. Okay. 9 Q. -- and that was first line support. 10 A. Correct. 11 Q. From an IT background, how would you describe the 12 purpose of first line support? 13 A. From an ITIL perspective, it's intended to be the single 14 point of contact for clients to interact with 15 an organisation, be that for software, hardware, or 16 general queries. The desk should then log the incident, 17 so that it's captured from a volumetric perspective, 18 attempt to troubleshoot and resolve at first point of 19 contact, if not possible to resolve, then to refer that 20 through to second or third line support, depending on 21 the processes. 22 Q. So one of the purposes is to try to resolve the issue at 23 first line and then, if not possible, refer up to the 24 second line or third line? 25 A. Yeah. 5 1 Q. On the Post Office Account, second line support, we 2 understand, was provided by the Systems Management 3 Centre or SMC? 4 A. Depending on the nature of the incident, so second line 5 for hardware faults would be potentially engineering 6 services but for software, yeah, absolutely, through to 7 the SSC, I believe the team was called. 8 Q. So the SSC -- we have heard about the SSC at third line. 9 Do you recall the SSC, the System Support Centre? 10 A. I don't recall which was first and which was second and 11 which was third line. 12 Q. But for second line support, let's just deal with that, 13 as a matter of generality first, from an IT perspective 14 what does the second line support do, what is its 15 purpose? 16 A. The purpose of second line support is to take 17 an incident which can't be resolved at the service desk, 18 at first point of contact, and investigate further, 19 attempt to resolve and, if resolution is not possible, 20 then to pass that through to third line support. 21 Q. In terms of -- I'm not sure if you can say this as 22 a matter of generality, but in terms of proportions of 23 problems that should be resolved at first line or at 24 second line or at third line, is there a general rule of 25 thumb as to how many incidents should be capable of 6 1 being resolved by first line support and then second 2 line? 3 A. Speaking in general terms, no, it depends very much on 4 the nature of the service that's been provided, the 5 access that a service desk may have. So, no, I don't 6 believe it's possible to generalise to say how much 7 should be resolved at first point of contact. 8 Q. Please can we turn to your witness statement, and it's 9 paragraph 14, on page 4. You say that to explain your 10 role: 11 "... I will briefly outline Fujitsu Core Services 12 and Account model, as it was in existence when I was 13 employed by the company. At this point in time, 14 services in Fujitsu were either provided by Core 15 Services or were Account Owned Services." 16 Please could you explain what Fujitsu Core Services 17 were? 18 A. Absolutely. I tried to articulate in the following 19 paragraph, in paragraph 15. So Core Services were 20 services that would be provided to multiple accounts. 21 So the examples that I gave in paragraph 15 would be, 22 for example, the service desk or engineering services, 23 and the reason for that was that they were activities 24 that could be customised for particular accounts. So 25 a service desk has very much the same purpose for one 7 1 account as for another account; engineering, again, very 2 much the same purpose for one account or for another 3 account. 4 So Fujitsu, at the time, had the model of having 5 these Core Services accounts and then anything that was 6 very specific to an account, for example, in Post 7 Office, would be part of the account team. One of the 8 key differentiators there is the fact that the resource 9 and the management of those services resided with Core 10 Services and the Core Services management structure, 11 whereas any account owned services resided with the 12 account for its management and its performance levels. 13 Q. You're quite right. You do say in your statement that 14 the Helpdesk was a core service. So does that mean that 15 the people who were dealing with Helpdesk enquiries, 16 sitting on the phones, would also be dealing with calls 17 related to different accounts? 18 A. No. 19 Q. No? 20 A. So they were ring-fenced resources that were dedicated 21 to Post Office, they were trained to support the Post 22 Office Account. But the management structure was under 23 Core Services. So the operations manager sat in Core 24 Services, again ring-fenced for Post Office Accounts. 25 There were other accounts sitting in Core Services where 8 1 there were shared services but Post Office Account was 2 not one of those. The resources were dedicated to Post 3 Office Account or supporting Post Office. 4 Q. On that point, please could we bring up FUJ00080478, 5 page 8, please. This is a document concerning the 6 Horizon Service Desk and described as a joint working 7 document. If we could just go to the bottom of this 8 page, please, just to get the date. It's 4 September 9 2008, and if we could focus in on paragraph 2.4, please. 10 It says: 11 "Fujitsu Services may provide a non-dedicated 12 service desk function sharing the resource with other 13 Fujitsu Services customers as described within this 14 Service Desk, Service Description." 15 So is it the case that Fujitsu may be entitled to 16 have a service desk which dealt with other Fujitsu 17 accounts? 18 A. Mm-hm. 19 Q. But from your time there and your recollection, it did 20 not, in fact, do that? 21 A. Absolutely. Absolutely. I guess that's the nature of 22 Core Services. Shared services desks could be put in 23 place but for Post Office Account it was a dedicated 24 desk due to the size of the account. 25 Q. Do you recall how many people were available to work in 9 1 the Helpdesk whilst you were working there? 2 A. I don't have the recollection as to how many people. 3 Q. Do you recall the types of minimum qualifications that 4 a person would need to be employed on the Horizon 5 Helpdesk? 6 A. Again, I don't recall the qualifications. I wasn't 7 involved in the selection of the resources to go on to 8 the Service Desk. I can speculate that it was due to -- 9 it was the client engagement, the ability to communicate 10 effectively with end callers, to be able to deal with 11 sometimes challenging conversations, but -- and IT 12 experience, and again that would be my speculation based 13 on my experience of running other service desks. 14 Q. Would you -- again I appreciate you don't have knowledge 15 of what these people actually required or what the 16 qualifications were, but in terms of -- from your 17 experience, would you expect that people working on the 18 Helpdesk would need some form of IT qualification? 19 A. Yes. 20 Q. What level would that be? 21 A. Again, it depends on the service desk that's being 22 supported and the level of technicality of the service 23 desk, but fundamental understanding of IT services would 24 be, in my opinion, a requirement to be on an IT service 25 desk. 10 1 Q. Was there anything about this Helpdesk, the Horizon 2 Helpdesk that took it out of the norm that meant more 3 advanced qualifications were needed or less? 4 A. No. The opposite. The Horizon Service Desk, from my 5 recollection, had very limited opportunity to resolve at 6 the first point of contact. So, from my recollection, 7 a lot of the calls that came through were related to 8 hardware, a reboot was the maximum that the Service Desk 9 could do there and that would be dispatched to 10 engineers. 11 There was also a Knowledge Base that laid out 12 step-by-step instructions as to what the Service Desk 13 could do. But to my -- the best of my recollection, the 14 IT Service Desk, the Horizon Service Desk was not 15 a technical service desk, not particularly technical. 16 Q. I certainly want to come to explore some of those issues 17 shortly. Before doing that, do you recall the training 18 that was made available to members of the Horizon 19 Helpdesk? 20 A. I don't. I know that there was training and I refer to 21 that in my statement. I know there was a training 22 programme put in place. I don't recall the duration nor 23 do I recall the contents of that. 24 Q. Do you know who would be responsible for ensuring that 25 members of the Horizon Service Helpdesk -- sorry, 11 1 Horizon System Helpdesk, were properly trained? 2 A. The operations manager for the Horizon Service Desk in 3 Core Services. 4 Q. Who was that during your time there? 5 A. Paul Gardner, ^name I believe was his name. 6 Q. Before moving on, if you can help us with this core or 7 account -- so Core Services or Account Services, do you 8 remember whether the second line support, SMC, would be 9 Core or Account Services? 10 A. I don't recall. I don't recall. 11 Q. Let's move to look at your role, then, as Service 12 Delivery Team manager. We don't need to bring it up but 13 paragraph 17(a) you say that you managed the team of 14 service delivery managers -- 15 A. Mm-hm. 16 Q. -- who provided both Core Services and account owned 17 services. How many people or service delivery managers 18 did you manage? 19 A. I believe it was around eight or nine service managers. 20 It changed over the two years. Eight or nine is my 21 recollection. 22 Q. How many of those would be responsible for work relevant 23 to the Horizon Helpdesk? 24 A. I had one service delivery manager who was the key 25 interface for the Horizon Service Desk. 12 1 Q. Who was that? 2 A. I don't recall his name, the role changed. Ian Mills, 3 I believe, at one point was involved in the Horizon 4 Service Desk. I don't recall the name. 5 Q. What was his day-to-day responsibility for the service 6 desk? 7 A. So he would interface with -- he would almost be the 8 conduit between the account team and the Core Services 9 team that provided the Horizon Service Desk. So he 10 would -- Ian or other people who held that role -- would 11 be looking at the metrics -- the Service Desk metrics in 12 terms of average speed of answer, dealing with any 13 escalations that came through, making sure that the Desk 14 was resourced appropriately. So he would work very 15 closely within the operations manager for the Horizon 16 Service Desk and also interact -- he was the 17 representation and interaction with Post Office, as 18 well. We had operational reviews around the Horizon 19 Service Desk performance. 20 Q. Did the operations manager report to you? 21 A. Paul Gardner? 22 Q. Paul Gardner? 23 A. No. 24 Q. Who did Paul Gardner report to? 25 A. His management structure in Core Services. 13 1 Q. Who did you report to? 2 A. The head of service delivery management for Post Office 3 Account. 4 Q. Let's look, then, in more detail at the Helpdesk itself. 5 Please can we look at your witness statement again, 6 page 5, paragraph 17(a). You set out your role "To 7 manage a team of SDMs" and, in respect of the Horizon 8 Service Desk: 9 "... involved engaging with the Core Services 10 Operations Manager to ensure delivery against the agreed 11 performance metrics of the first-line desk, and 12 improvement of the service. Ensuring that the Core 13 Service function was in line with the profit and 14 loss/business case, the [Horizon Service Desk Service 15 Delivery Manager] also managed escalations from [Post 16 Office Limited] on the performance of the Service Desk 17 with the Core Services Team." 18 A. Mm-hm. 19 Q. So is it fair to say in terms of both -- your 20 responsibilities were both for the volumetrics, in the 21 sense of how many calls were answered, the speed of the 22 calls. 23 A. Mm-hm. 24 Q. Was the quality of the advice provided also within your 25 responsibility? 14 1 A. Yeah, so to clarify, the actual achievement of those 2 performance metrics sat with the operations manager in 3 Core Services, as did the quality. In the event that 4 those metrics dropped down or the quality dropped down, 5 that would then be discussed by myself and by the 6 Horizon Service Desk SDM and we would work 7 collaboratively with Core Services to implement 8 improvements to address the quality metrics or to 9 address the performance metrics as well. 10 And, as mentioned in my statement, if we received 11 escalations from Post Office on the quality or on the 12 performance metrics, we would work collaboratively to 13 address those. So there were three parties involved in 14 the process: the Core Services team, the account team 15 and Post Office Limited. 16 Q. Just to make sure I've got this, the operations manager, 17 Paul Gardner, he had day-to-day responsibility for 18 ensuring that the quality and volumetrics were to the 19 required standard? 20 A. Yes. 21 Q. You would monitor that -- 22 A. Mm-hm. 23 Q. -- and step in when there was a drop -- 24 A. Mm. 25 Q. -- and come up with ways or devise strategies to improve 15 1 it to get it back to the contractually agreed level of 2 service? 3 A. Yeah, there was almost the layers-off accountability. 4 So Paul was accountable for the Service Desk, myself and 5 my team were accountable to Post Office for those 6 quality and the service metrics. We had to make ensure 7 the service was delivered in line with the contractual 8 metrics. 9 Q. So in doing that role, whilst not immediately day-to-day 10 responsible for the service desk, you had awareness of 11 its operation and its function? 12 A. Absolutely, yeah. 13 Q. Turning then to its function, you state in your witness 14 statement, you say that -- this is paragraph 20: 15 "The HSD was primarily a log and flog function, as 16 there were very limited first line/level fixes that the 17 desk could complete." 18 A. Yeah. 19 Q. Can I ask you to expand on "log and flog"? 20 A. Yeah, so as referred to, the Horizon Service Desk really 21 had limited opportunity to resolve at first point of 22 contact. So log and flog is a generic term used in the 23 industry which is basically to log a ticket and then 24 pass it through to the next level of support, be that 25 hardware, software or query management. 16 1 Q. Why were there such limited first line fixes available 2 for the Horizon Service Desk? 3 A. So a large number of the incidents that were logged were 4 hardware related. Again, as I've articulated, very 5 little could be done on a hardware issue, apart from to 6 try and reboot the counter. If the counter was down, 7 that caused issues for the Post Office. So the approach 8 that was taken if the reboot didn't work -- and that 9 normally took about 20 minutes -- we'd dispatch the 10 engineer to get an engineer on site as quickly as 11 possible to allow the branch to trade again. 12 Single-counter branches was obviously more critical 13 than multi-counter branches. Again, with keypads -- 14 and, again from my understanding, there was very limited 15 software fixes that the desk could do anyway because 16 I don't believe they had access to fix anything with the 17 software. They'd look in the Knowledge Base, if there 18 was no immediate resolution that was documented in that, 19 they would then pass that through to the second line 20 support or third line support. 21 Q. Again, something else that we will come to in due course 22 but the types of calls, let's just cover that for 23 a moment. You said there were a lot of hardware calls? 24 A. Mm-hm, yeah. 25 Q. The Inquiry has heard a significant amount of evidence 17 1 from subpostmasters who stated that they faced 2 discrepancies in their accounts, which were generated by 3 Horizon. Do you recall there being a significant number 4 of calls relating to discrepancies which came in to the 5 helpdesk? 6 A. I would only have the classification of which the ticket 7 was logged against, the PowerHelp codes. I don't 8 know -- from best of my recollection, I'm not sure there 9 was a code that specifically called out discrepancy. So 10 I don't know. From my recollection, the bulk of the 11 calls that came through were hardware related calls or 12 branch services were offline, as in the BT network that 13 was put in place to the Post Office was offline, which 14 meant the branch couldn't trade. 15 Q. Please can we just bring up paragraph 41 of your witness 16 statement at page 16. Thank you. Here you say that: 17 "As a result of some of the escalated incidents, 18 which I directed to the Software Team, I was aware that 19 it had been reported by SPMs that the system could cause 20 branch discrepancies, however I do not recall these in 21 detail." 22 A. Mm-hm. 23 Q. Can you just summarise when you would become involved in 24 these escalated incidents, in your role? 25 A. Yeah, escalations generally came from two sources, one 18 1 was Post Office would escalate to me directly or the 2 Service Desk would escalate to the Service Delivery 3 Manager for that function, and then they would escalate 4 to me if they were unable to resolve that escalation. 5 Q. You say there you were aware of the reports of SPMs 6 saying that the system could cause discrepancies. 7 A. Mm-hm. 8 Q. Was that common knowledge in the Helpdesk, of the fact 9 that SPMs were making such allegations? 10 A. I'm unable to comment on whether the Service Desk 11 thought this was common knowledge or not. As I say, 12 the -- I really have no recollection of whether I knew 13 that or not. 14 Q. Stepping back, then, from the Service Desk, amongst your 15 colleagues you worked with day to day, was it a known 16 fact that allegations by SPMs were being made that the 17 Horizon System could cause discrepancies? 18 A. Again, it's not an area that I was particularly involved 19 in. I think there was some awareness that there were 20 discrepancies but, again, I'm not sure of how widely 21 that was known, nor did I have any understanding about 22 the scale of discrepancies that could be caused. 23 Q. Are you aware of anything that was done to investigate 24 those allegations within Fujitsu? 25 A. Not personally. As I say, my portfolio wasn't around 19 1 the software. It's my speculation that it was being 2 investigated by the second and third line support teams 3 in the software side of the support. 4 Q. I want to look at one of those escalations now, and turn 5 to a document which you were given this morning. It's 6 POL00028984. If we could go to page 10, please, at the 7 bottom. This is an email that the Inquiry has seen 8 before. It's from Sandra MacKay to Shaun Turner. It 9 says: 10 "Shaun, you may recall that in September the above 11 office had major problems with their Horizon system 12 relating to transfers between stock units." 13 Go over the page, please. Thank you. 14 The SPMR has reported that he is again experiencing 15 problems with transfers, (5 January '06) which resulted 16 in a loss of around [£43,000] which has subsequently 17 rectified itself. I know the SPMR has reported this to 18 Horizon Support, who have come back to him stating that 19 they cannot find any problem." 20 If we could go then to page 8, please, and to the 21 bottom. There's an email there from Gary Blackburn to 22 you on 15 February 2006. Do you recall Gary Blackburn? 23 A. I do, yeah. 24 Q. Who was he? 25 A. He worked on Post Office. I can't recall his exact role 20 1 but he was one of three or four people that I had 2 regular contact with on the Post Office Account. 3 Q. He forwards this email on to you -- 4 A. Mm-hm. 5 Q. -- describing the detail, and says: 6 "... could you please update me on the corrective 7 action plan as this still appears to be occurring within 8 the branch." 9 Do you have any recollection of this matter? 10 A. No, the first I remember of this is when this document 11 was presented to me this morning. 12 Q. If we go above, your response is -- just move up 13 slightly so we can see the date, please. Thank you. 14 On 16 February, you say: 15 "Hi Gary, 16 "I have checked the call and this issue is scheduled 17 to be resolved in S90." 18 Do you recall what S90 was? 19 A. I don't. 20 Q. If I said it was a release, a software release? 21 A. I assume it's a release, yeah. I don't recall 22 specifically what it is, no. 23 Q. I appreciate you say you can't recall this incident at 24 all, but how would you have gained this information to 25 come back to Gary Blackburn with this response? 21 1 A. I would have spoken to the second or third line support, 2 third line in this case, for the Software Support Team. 3 Q. Do you think you would have been concerned that the 4 Helpdesk had initially advised the postmaster that this 5 discrepancy was not a fault in the system when it 6 transpired that it was a software problem? 7 A. Yes, I believe I would have been concerned. The Horizon 8 Service Desk would have followed whatever was in the 9 knowledge database, so I would have been concerned that 10 the information in the knowledge database would have 11 been incorrect and that incorrect advice would have been 12 given to the subpostmaster or the postmaster. 13 Q. Can you recall if any steps were taken to address that 14 concern? 15 A. The KELs, the knowledge articles, were updated on 16 a regular basis. They weren't updated by the Service 17 Desk, again, so I can't recall if anything specifically 18 happened in relation to this particular incident. 19 However, there was a process to make sure that the KELs 20 were updated with the latest information. 21 Q. When KELs were updated like that, was it simply a case 22 of there's a KEL on the system, an update has been made, 23 so the next time someone accesses that KEL, they will 24 see updated information, or was there a circular sent 25 round to members of the Helpdesk to advise them of any 22 1 updates? 2 A. Um, again, I don't recall in detail. I know the KELs 3 would have been updated and that information, the latest 4 information, would have been visible. To the best of my 5 recollection, there was a process whereby information 6 was circulated round the Service Desk but that wasn't 7 for every single KEL that was updated. 8 Q. Do you have any recollection of which KELs would be -- 9 A. I'm afraid I don't, no. 10 Q. At page 5 of the document, if we can go down slightly 11 please to the bottom -- thank you -- we see Gary 12 Blackburn emails you back on 17 February. He's got some 13 questions, which are over the page. 14 In particular, one of them is: 15 "Do we understand why this particular branch has 16 been having problems? Or are there other branches in 17 the network that have been having this problem?" 18 If we go back to, I think, page 5, you send that on 19 to Mike Stewart. Do you remember who Mike Stewart was? 20 A. Yeah, he was a Service Delivery Manager who reported to 21 myself and worked on online services. 22 Q. What was the purpose of sending this to him? 23 A. So he was closer to the applications and the systems to 24 be able to investigate that. So it was common that 25 I would then distribute the work to the people who had 23 1 more knowledge around the content of the email. 2 Q. Do you recall, after sending this email, if you had any 3 more involvement with this issue? 4 A. I don't recall the email. So, no, I don't believe I had 5 any further involvement. From what I can see from the 6 emails, I was even taken off the email exchange. 7 Q. Can we go to page 3, please, and the email from Anne 8 Chambers to Mike Stewart on 23 February. This isn't 9 an email -- well, there's no evidence here to suggest 10 you were sent this at the time. I just want to look at 11 the second paragraph though, which says: 12 "Haven't looked at the recent evidence, but I know 13 in the past this site had hit this Riposte lock problem 14 2 or 3 times within a few weeks. This problem has been 15 around for years and affects a number of site most 16 weeks, and finally Escher say they have done something 17 about it." 18 So this is, is it fair to say, talking about 19 a fairly significant bug in the Horizon System code? 20 A. It appears that way, yes. 21 Q. Were you aware of this at the time at all? 22 A. As I say, the only recollection I have now is from this 23 email that was sent to me, was provided to me this 24 morning. Until this point in time, I'd no recollection 25 of the Callendar Square issue nor this Riposte lock 24 1 problem. 2 Q. If this information had been given to you at the time, 3 do you think it's something that you would have 4 remembered now? 5 A. Absolutely. Because, you know, it's a significant issue 6 and I would have absolutely done to the best of my 7 ability to make sure we investigated that properly. So 8 yeah and that's because of the person I am. So ... 9 Q. Thank you. That document can come down now. 10 We'll move on to a different matter which is the 11 types of calls you were referring to earlier, and if we 12 could bring up FUJ00083429. This is a Fujitsu Services 13 Post Office Account Service Review Book for February 14 2007. Can you briefly summarise what this document was 15 or the purpose of these types of document. 16 A. Yeah, it was a contractual obligation that each month 17 the Fujitsu Post Office Account had to provide this 18 through to Post Office and it outlined the performance 19 metrics for the key services that Fujitsu provided. So 20 there were performance metrics and commentary included 21 in there. 22 Q. Please can we turn to page 11. This is showing the 23 Horizon Service Desk, the table, unhelpfully in black 24 and white, but we can come to the numbers further down, 25 but is this showing that -- essentially showing the 25 1 metrics for from February '06 to February 2007 -- 2 A. Yeah. 3 Q. -- for the service level agreements? 4 A. No, this is showing the number of calls in each of those 5 categories, so the number of calls was not the service 6 level agreement. The service level agreement was more 7 around average speed of answer. Number of calls that 8 went through to voicemail, for example, I believe those 9 are listed in one of the statement of work documents. 10 Q. If you could go to the bottom of this page, please, and 11 if we could make the table at the bottom just slightly 12 bigger -- thank you. 13 So we see the total calls, third up from the bottom, 14 and a monthly call limit. 15 A. Mm-hm. 16 Q. What was the monthly call limit? 17 A. I don't recall specifically. I could speculate that 18 that's the document -- that was a contractual level was 19 put into a document, so that if we -- if the number of 20 calls exceeded or significantly were less than this, it 21 would trigger a conversation with Post Office around the 22 volumetrics of the service desk and the cost of the 23 service. It's standard for IT to have those threshold 24 limits in there. 25 Q. We see that the calls range in February '06 is just over 26 1 13,000, to this 16,000 in January '07, 15,500 in 2 February '07. 3 A. Mm-hm. 4 Q. In terms of the breakdown of different types of calls 5 in, significant numbers for hardware? 6 A. Yeah. 7 Q. At the bottom, there is a collection for -- or 8 a category for software, as well. Can you recall or 9 where -- we discussed discrepancies earlier. Which 10 category do you think discrepancies would fall into, 11 reported discrepancies? 12 A. My assumption is that they would fall under software. 13 Q. Thank you. That document can come down. If we could 14 bring up FUJ00001966. This is a document dated 15 19 August 2005. So "Service Level Targets for Horizon 16 Services". 17 A. Mm-hm. 18 Q. So drafted just before, I think, you started on the Post 19 Office Account? 20 A. Yeah. 21 Q. At page 8, please, we have the service level targets 22 for, at the bottom, Horizon System Helpdesk. 23 A. Yes. 24 Q. The first three are, I think, to do with calls answered 25 and the proportion there? 27 1 A. Mm-hm. 2 Q. We then have "Level 1 calls resolved within 5 minutes", 3 95 per cent; do you recall what a level 1 call was? 4 A. I don't recall exactly what a level 1 call was, however 5 it was something that would be able to be resolved at 6 the Service Desk. 7 Q. The same for level 2, really. Do you recall the 8 difference between that and a level 2 call? 9 A. So, again, a level 2 call, again, I don't recall. So 10 that would be something that -- within the Service Desk, 11 there was a level 1 and a level 2 sort of level of 12 service. So level 2 probably had more time. They took 13 more time to see if they could resolve at first point of 14 contact. Obviously, it's much more advantageous for 15 post offices and for Fujitsu to resolve at the Service 16 Desk rather than pass to a second or third line support 17 team. 18 So seeing this now has triggered the memory in me 19 that there was a level 1 and level 2 Service Desk within 20 the Horizon Service Desk. I don't recall the difference 21 between a level 1 and level 2 call. 22 Q. So this is saying of level 1 calls, say, for example, 23 95 per cent should be resolved within five minutes and 24 for level 2 calls, those defined as level 2, 95 per cent 25 should be resolved within 30 minutes. Can you recall if 28 1 there were any targets or guidelines of the proportion 2 of calls which come into the Helpdesk which should be 3 level 1, which should be level 2 or which should be 4 level 3? 5 A. No, I've no recollection of that. 6 Q. That document can come down, thank you. That monitors 7 how the Helpdesk in terms of volumetrics responded. How 8 was the quality of the Helpdesk advice actually given, 9 how was that monitored? 10 A. So there was -- I believe they were called service 11 controllers or the team leaders would monitor and listen 12 into calls. That was then given feedback specifically 13 to agents. Again, I don't recall the percentage of 14 calls that were listened in to but that was part of 15 general Service Desk practice. There was also 16 a complaints process. So when we received a complaint 17 or the Horizon Service Desk would receive a complaint, 18 that would then be logged and that would be investigated 19 to determine if the complaint was a valid complaint or 20 not. 21 Q. Let's move to that assistance and how that was given. 22 Can we bring up FUJ00079939. This is a "[Post Office 23 Account] Customer Service Incident Management Process" 24 definition, drafted on 23 March 2005. This is for what 25 we've called Legacy Horizon, or what's known as Legacy 29 1 Horizon, the version of Horizon in place from national 2 rollout until 2010. 3 A. Mm-hm. 4 Q. You drafted the Horizon Online version of this document; 5 is that right? 6 A. Yeah, that's correct. 7 Q. But this is the document that you would have been 8 working with or would have been used at the time that 9 you were in post? 10 A. Yeah, this was drafted just before I joined but, yes, 11 this is the process that we would have been working to. 12 Q. If we could turn to page 8, please. The "Process 13 Objective", under 1.2 says: 14 "The objective of this document is to define the 15 process for Incident Management of the POA environment. 16 For the purpose of this document an Incident is defined 17 as: 18 "'Any event which is not part of the standard 19 operation of a service and which causes, or may cause, 20 an interruption to, or a reduction in, the quality of 21 that service'." 22 So if a subpostmaster called the Helpdesk with 23 a possible software problem, that's an incident to be 24 managed under this process; is that right? 25 A. That's correct, yes. 30 1 Q. Can we turn to page 12, please. So we have a flowchart 2 here showing at the top, entry ways into the contact 3 received by the POA Service Desk. "SDU", is that 4 Service Delivery Unit? 5 A. Correct, yeah. 6 Q. In lay terms, what would a Service Delivery Unit be? 7 A. So the software support, the SSC was a Service Delivery 8 Unit. So it was a team, a resolving unit, if you like, 9 a resolving team that would work to resolve incidents. 10 Q. So a team within Fujitsu such as the SSC or the -- 11 A. Yes, or engineering, yeah. 12 Q. There's then "User", which is presumably the 13 subpostmaster? 14 A. Mm-hm. 15 Q. "System" and "Service Management". Do you know what 16 those are? 17 A. So we could have system driven alerts that would come up 18 in. From my recollection they would come from the data 19 centres, if there were any system alerts that could 20 trigger an incident being logged at the Service Desk, 21 and service management would be myself, my team and the 22 wider service delivery organisation. Users would also 23 be Post Office Limited, as well, so not just necessarily 24 just subpostmasters, just for clarification. 25 Q. No, and we don't need to go through all of this 31 1 flowchart. It starts with trying to triage the query, 2 basically. At the bottom we see, if we just move down 3 slightly, four types of outcome. There's "Incident", 4 which then follows this process in this document; 5 "Advise & Guidance, Answer enquiry and close or refer to 6 ... NBSC"; "Out of Scope", that's where -- it wasn't 7 within the scope of the services provided by Fujitsu? 8 A. Correct. 9 Q. And "Quality". 10 A. Mm-hm. 11 Q. Is "Quality" looking at the quality of service provided 12 by the Helpdesk rather than the quality of the Horizon 13 System? 14 A. From my understanding of the document, yes. 15 Q. On the helpdesk, how would the -- what process was used 16 or guidance was used for allow a Helpdesk operator to 17 decide whether it's an incident or something that needs 18 to go to the NBSC? 19 A. So the service desk would have had call scripts that 20 they would go through and that would help them then 21 determine which of these four categories the incident 22 would be logged -- or not necessarily the incident, 23 which of the four categories would be applicable in this 24 process. 25 Q. I'm just going to move forward, actually, because you've 32 1 mentioned call scripts now and I think in your statement 2 you say that the agents were provided with scripts, 3 pre-defined questions, which they were expected to use 4 when providing support to the SPM. 5 Do you recall who was responsible for drafting those 6 scripts? 7 A. The Service Desk team would have been responsible for 8 drafting those scripts, however they would have had 9 input from the Service Delivery Units or from service 10 delivery management as well. 11 Q. Where were they held for the operators to access? 12 A. I don't know where they were held. I don't know where 13 that documentation was held. I don't recall if it was 14 actually part of the PowerHelp tool set. In some 15 service management tool sets, the script is actually in 16 the software, so it prompts the agent what to say. But, 17 in this instance, I don't recall where it was held. 18 Q. Do you recall if there was a general script to follow 19 for all calls or if there were individual scripts for 20 specific issues raised by subpostmasters? 21 A. Again, I wasn't actively involved in the day-to-day 22 operation of the desk. My recollection is that there 23 was a script that initiated the conversation, you know, 24 greeting the caller, getting the Post Office branch 25 ID -- again, I can't remember the correct terminology 33 1 for that -- and then obviously trying to capture 2 specific information. I think one of the documentations 3 has that in there, one of the joint working documents 4 actually lists out some of the scripts that needs to be 5 said. 6 Q. I may have the document in my mind, which you're 7 referring to. Shall we bring up FUJ00080478. This is 8 a Horizon Service Desk joint working document, and we 9 see at the bottom the -- you were an author on this with 10 John Casey. 11 A. Yes, so John was one of the service desk managers 12 reporting into Paul Gardner. 13 Q. Please can we turn to page 13. This section looks at 14 the end-to-end incident management and if we go down 15 slightly, under 4.4.1, the third paragraph down, it 16 says: 17 "The moment an Agent receives an incoming telephone 18 call, they will greet the customer with the example 19 shown below. All spoken words are marked in Italics and 20 'quotes'. 21 "'Good Morning/Afternoon/Evening. Horizon System 22 Helpdesk [AGENT NAME] speaking. 23 "'May I take your Branch code please?'" 24 A. Yes, and this would have been part of the training that 25 was given to the Service Desk agent before they took 34 1 live calls. 2 Q. Are you aware if this document was converted into a more 3 precise script that would then be used by the Helpdesk? 4 A. I am not personally aware but it would be my speculation 5 that it was. This is, you know ... 6 Q. Please could we bring up now FUJ00138733. I think this 7 was a document you were given this morning. 8 A. Mm-hm. 9 Q. It's: 10 "PROCESS -- ID:408501 -- Engineer Refused Access 11 Process. 12 "Summary: 13 "Please use this KA ..." 14 Do you know what "KA" stands for? 15 A. I don't know, no. Knowledge article, perhaps I would 16 hazard a guess at. 17 Q. Knowledge article. That's what I was about to suggest. 18 A. Yeah. 19 Q. But: 20 "... if an engineer has called to advise they have 21 been refused access at a post office. 22 "Resolution: 23 "If an engineer has called to advise that they have 24 been refused access at a post office, please follow the 25 below: 35 1 "Frontline Process ..." 2 Then 2 says: 3 "HSD contacts site and follows call script below in 4 purple." 5 We don't then need to read it out but there is then 6 a call script there for a specific incident, in this 7 case engineer refused access process. Do you recall 8 seeing items like this during your time working with 9 Fujitsu? 10 A. No, I don't recall seeing this. Again, I can speculate 11 that this is the knowledge article that the Service Desk 12 had, that would -- they would refer to this in the event 13 that they received a phone call from an engineer saying 14 they didn't have access to the site. 15 Q. Would you anticipate that there would be similar 16 articles for -- this is obviously engineer refused 17 access but say a subpostmaster rang with a discrepancy 18 would you expect there to be scripts of a similar nature 19 advising the operator how to deal with that? 20 A. It would be my expectation, yes. 21 Q. That document can come down. Thank you. 22 Do you recall ever an instruction being given to 23 helpdesk staff to tell subpostmasters that they were the 24 only person experiencing a problem that they had 25 reported? 36 1 A. No. 2 Q. Would you expect -- what would you say if such advice 3 was given? 4 A. I would say that would be erroneous advice. 5 Q. If we could please bring back up FUJ00079939. If we 6 could go to page 15, please, paragraph 2.4. This sets 7 out, I think it's fair to say, what the Service Desk was 8 expected to do when handling calls or incidents and, for 9 the record, it says: 10 "The Service Desk agent then attempts to resolve the 11 Incident using the resources available. This starts by 12 interrogating HSH ONE ..." 13 Do you recall what that was? 14 A. I don't recall. Again, I can speculate that that was 15 the term given to the system that housed the KELs or it 16 was a precursor to the knowledge database. That's 17 a terminology that I don't recall. 18 Q. "... to find all information related to the Incident 19 symptoms. If the Incident is routine, ie there is 20 a pre-determined route for resolution, then the Incident 21 is referred to the relevant SDU using the Service Desk 22 Support Matrix in HSH ONE." 23 When you say "SDU", that would be perhaps the SMC or 24 engineering? 25 A. Or engineering, yeah. 37 1 Q. It then goes on to say: 2 "If the Incident is not routine, the Service Desk 3 agent checks for Known Errors listed in HSH ONE and the 4 SSC KEL against records relating to the Incident 5 symptoms. If a match is found, the agent informs the 6 caller of the workaround or resolution available and 7 links the call to the master Incident record." 8 A. Mm-hm. 9 Q. Do you recall the KEL database? 10 A. Not in detail, I recall its existence. 11 Q. Do you recall whether members of the helpdesk found that 12 an easy system to use? 13 A. I wouldn't be able to comment on that. I don't know. 14 Q. During your time analysing the call metrics, et cetera, 15 would you have needed to consider, for example, if there 16 was an increase in delays in resolving calls within 17 10 minutes or 30 minutes, would that be something you 18 would look into, the reasons for the delay, sorry? 19 A. Yeah, for the level 1, level 2 on the Service Desk. So 20 anything that got routed to a Service Delivery Unit, the 21 only one that I would have had any involvement in is the 22 engineering service and anything that was rooted to 23 Cable & Wireless or BT for the online branch services -- 24 it wasn't Internet -- ADSL as it was at the time, but 25 I wouldn't look into any of the software calls. 38 1 Q. Who would look into the software calls? 2 A. The SSC would be my assumption. 3 Q. So let me look -- put this a different way. When 4 examining whether a software -- a number of software 5 calls had been resolved quickly enough and within 6 service level targets, would you ever have looked into 7 whether the KEL database was an effective way or was 8 effective in giving Horizon Service Helpdesk operators 9 information they needed to resolve level 1 and level 2 10 calls? 11 A. The only metrics that I'd have looked into were the 12 level 1, level 2 within the Horizon Service Desk. So 13 the -- I don't know what the resolution timescales or 14 the SLAs were expected to be for the Service Delivery 15 Units that were not part of my portfolio. So I don't 16 know what the SSC SLA was or what it was intended to be. 17 But going to the question, looking at level 1, level 2 18 within the Horizon Service Desk, if we saw deterioration 19 or that service level metric wasn't being met we would 20 look to try to understand what was the root cause of 21 that. 22 MR STEVENS: Sir, I don't have much longer to go but, for 23 the transcriber, I notice we've been an hour, so 24 I wonder if we could have a short break? 25 SIR WYN WILLIAMS: Yes, by all means. Where are we now? 39 1 11.30 all right? 2 MR STEVENS: Yes, that's fine, thank you, sir. 3 SIR WYN WILLIAMS: Good, see you then. 4 MR STEVENS: Thank you. 5 (11.13 am) 6 (A short break) 7 (11.30 am) 8 MR STEVENS: Sir, can you see and hear me? 9 SIR WYN WILLIAMS: Yes, I can, thank you. 10 MR STEVENS: I want to go back to the document we were on 11 and at the same place, please. It's FUJ00079939. And 12 paragraph 2.4 -- sorry, 2.5. We went to this paragraph 13 beforehand and this is where the Service Desk operator 14 couldn't resolve the problem of using HSH One -- 15 A. Mm-hm. 16 Q. -- and then checked for known errors listed in the same 17 database but also in the SSC KEL database that we 18 discussed? 19 A. Yeah. 20 Q. It said: 21 "If a match is found ..." 22 So presumably if it matches to something in the One 23 system or in the SSC KEL system: 24 "... the agent informs the caller of the workaround 25 or resolution available and links the call to the master 40 1 Incident record." 2 A. Mm-hm. 3 Q. Can you just explain what the master incident record was 4 in that case? 5 A. So it's common practice in the Service Desk to create 6 a master incident record and then append what we call 7 child incidents to that master record. That then allows 8 any Service Desk or, in this case, the Post Office 9 Service Desk, to be able to capture the metrics on how 10 many occurrences of that incident there actually were, 11 if that makes sense. So it's a mechanism of saying we 12 have this major incident, and then there's appended 13 other incidents beneath that. 14 Q. So for instance with Callendar Square -- I'm not saying 15 this is what happened but to use it as an example, there 16 may be a master bug or incident and then each time one 17 is identified in the field, in theory, that should be 18 appended to that incident as a child? 19 A. That's the theory, yes. 20 Q. Is that different to the KEL, so would the KEL be 21 updated to show that the call had been raised and was 22 linked to the overall KEL? 23 A. There would be a cross-reference between the KEL number 24 and the number of incidents. So, again, this is my 25 assumption, that the master incident record would refer 41 1 to the KEL and, therefore, you would be able to 2 extrapolate that KEL12345 had X number of incidents 3 associated with it. 4 Q. So, in this case, if there was a second incident of 5 a similar or the same materialisation of a bug, we had 6 the child. You think that the -- there's a link to the 7 actual KEL, so on the KEL you can see incidents linked 8 to it. Are you aware if that ever changed? 9 A. So just to clarify, I'm not sure that the KEL would show 10 the number of incidents but you could cross-reference 11 the two data sources to achieve the same outcome, so 12 just for clarity -- and sorry, what was the second 13 question? 14 Q. That system that you've just referred to, are you aware 15 if that ever changed during your time at Fujitsu? 16 A. I don't believe so, no. 17 Q. Thank you. Can we turn to page 16, please, and 18 paragraph 2.6: 19 "If there is no match in HSH ONE or the SSC KEL, the 20 Problem Database is checked for current incidents 21 outstanding. If a match is made, the caller is then 22 advised of the status of the Problem and the call is 23 then linked to the master Incident record given in the 24 problem details. 25 "2.7. If no match is made against the Problem 42 1 Database, the Service Desk continues with first line 2 resolution of the Incident assisted by the Product 3 Support Engineers ..." 4 Who were the product support engineers? 5 A. I don't recall who the product support engineers were in 6 this particular instance. Again, I could speculate that 7 they are subject matter experts associated with the 8 particular software or hardware but I don't recall 9 specifically who the PSEs were in this particular 10 instance. As it's articulated here, it appears that 11 they're part of the Service Desk. 12 Q. So and then 2.8: 13 "If the PSEs cannot resolve the Incident, it is 14 referred to the relevant SDU using the Service Desk 15 Support Matrix in HSH ONE." 16 A. Yes. 17 Q. So is my understanding right that this, you follow this 18 process and then if this doesn't lead to a resolution, 19 it's then passed to second line support? 20 A. So what would happen is, if an incident is logged -- and 21 this is sort of generic service management best 22 practice -- if an incident is logged, it's then 23 validated to see if there's a known solution, a known 24 workaround to get the service restored. That's the KEL 25 that would be looked in. The KEL contained -- or the 43 1 knowledge database contains how to resolve an incident, 2 how to restore that incident. 3 The problem database would be open items for which 4 the resolution hasn't yet been identified. So problem 5 management is one level elevated to incident management 6 and then the product support engineers, reading this 7 now, they are subject matter experts in the Service Desk 8 and if they are unable to resolve, that's then when it 9 would get that then passed through to the Service 10 Delivery Unit, should that answer your question or not. 11 Q. I suppose my question is that's when it goes to second 12 line? 13 A. Mm-hm, yeah. 14 Q. So the Helpdesk -- in your experience, did the Helpdesk 15 follow this as a matter of course, in practice, this 16 system? 17 A. Yes, yeah, absolutely. That would be the system that 18 they followed. I can't say that they followed it 19 100 per cent of the time because there are humans 20 involved in this but that was absolutely the intent: to 21 check the KEL, to see if there was a resolution and then 22 to check the problem database and, if it was unable to 23 resolve, to assign it through to the SDU. The KEL might 24 actually stipulate in it "You need to pass it to the 25 Service Delivery Unit", so that could also be some of 44 1 the information that's in the KEL. 2 Q. Your evidence earlier when we discussed the log and flog 3 matter, you discussed how there weren't many first line 4 fixes available. 5 A. Mm-hm. 6 Q. When we explored that, you referred to the number of 7 hardware issues -- 8 A. Yes. 9 Q. -- and we saw the number of calls that came in to do 10 with hardware, so those calls would be, of course, 11 passed straight on to the engineering department or 12 whatever it is. 13 A. Yes. 14 Q. Limiting it to software complaints, was there still a 15 limited number of first line fix available to the 16 Helpdesk when this process was followed? 17 A. It's my belief that, yes, there would still only be 18 a limited number of fixes that the Service Desk would be 19 able to do. 20 Q. Do you know why that was? 21 A. Again, I -- my speculation is that they didn't have any 22 ability to resolve software incidents and they had to go 23 to the specialised teams. It's very few service desks 24 that are able to resolve software issues. Mostly it's 25 a reboot to see if that solves it but that's why it's my 45 1 belief that there was very limited first-level fix that 2 the Service Desk could do in software incidents. 3 Q. Were the types of software incidents that were being 4 presented to the Helpdesk more complex than you would 5 expect in other IT projects? 6 A. I'm unable to comment on that. Again, the information 7 I saw was the breakdown of the number of tickets logged 8 against specific PowerHelp codes. 9 Q. If we go to a different document, please. It's 10 FUJ00079897. It's a 2003 document, "End-to-End Support 11 Process, Operational Level Agreement". 12 A. Mm-hm. 13 Q. Please can we turn to page 6. This sets out 14 "HSH/HIT/SMC obligations to SSC". I think we've covered 15 all of those abbreviations, save for "HIT". Do you 16 remember what that was? 17 A. Well, according to the abbreviation definition in the 18 document it's the Horizon Service Desk Incident Team. 19 Q. Do you recall what their role was? 20 A. There was a subsection within the Service Desk -- the 21 Service Desk have -- it's not just agents that have 22 responded to calls. You also have team managers, PSEs, 23 as I now remember, and incident management teams. And 24 the incident management teams would look at major 25 incidents or significant incidents and make sure that 46 1 those were passed through to either the service 2 management team or managed in accordance with the 3 incident management process -- the major incident 4 management process. 5 Q. So this document is looking at what is described as 6 obligations for first and second line support 7 collectively to third line support? 8 A. Mm-hm. 9 Q. Subparagraph (d), it says: 10 "To 'filter' all calls for which the problem is 11 already known to the support community and for which 12 a resolution is already known or has been generated. In 13 this context the term 'resolution' can take a number of 14 forms, including. 15 "The statement that the problem is resolved in 16 release [X] of the Horizon solution. 17 "There is a documented workaround for the problem. 18 "The documentation relating to that part of the 19 system is under review or being changed. 20 "No calls passed to the SSC which are subsequently 21 resolved as known errors, except in cases where the 22 symptoms as reported by the customer did not match the 23 symptoms recorded in the known error documentation, and 24 which therefore the HSH/HIT/SMC could not reasonably 25 have been expected to find." 47 1 So this is essentially putting into practice what 2 you described earlier, that, where possible, first and 3 second line support should resolve the calls where they 4 can do? 5 A. Mm-hm. 6 Q. Are you aware if there was any consequences of or what 7 happened when the SSC considered that a call had been 8 directed up to them inappropriately? 9 A. Um, they -- my recollection is that they would refer 10 that back and we would try and have a closed loop 11 process to understand why a call had been passed to SMC 12 which -- or SSC, sorry, which shouldn't have actually 13 been passed there, because the intent is always to try 14 to resolve as quickly as possible. So that's a failure 15 in the process, if something has gone through to a third 16 line support team, which should have been resolved or 17 could have been resolved by a level 1 or a level 2 desk. 18 Q. To what extent was there pressure on people in the 19 Helpdesk to resolve calls themselves rather than refer 20 them up? 21 A. Um, again, I wasn't actively on the -- involved in the 22 day-to-day operation on the Service Desk. There was, 23 you know, there was a requirement for them to follow the 24 process correctly but I wouldn't say that there was 25 pressure on them to not pass calls through to second or 48 1 third line. You know, there was no metrics on that and 2 the desk was operating on its -- on the metrics that we 3 discussed in the previous documentation. So I don't 4 believe there was undue pressure or any pressure for 5 them to not refer calls inappropriately. 6 Q. Can we turn to page -- I think it's just over the page, 7 subparagraph (m). Just further down, please. We have 8 (m), which is: 9 "To 'filter' all user error calls and ensure that 10 they are closed. 11 "No calls passed to SSC which are subsequently 12 closed as 'user error'." 13 Then (o): 14 "To 'filter' all calls for which the Pathway 15 software [it says 'in' but 'is'] not at fault. 16 "No calls passed to SSC which are subsequently 17 closed as 'No fault in product'." 18 From the Helpdesk perspective, do you think the 19 people working on there had sufficient expertise to be 20 able to determine whether a call was -- or an incident 21 was caused by user error, rather than the software 22 itself? 23 A. The intent of the knowledge articles is to provide the 24 knowledge to the Service Desk agent, so that they should 25 follow the script that's in the knowledge article and 49 1 that would then determine whether it was -- how to route 2 the call. The intent of knowledge articles is to 3 eliminate that need for in-depth knowledge for Service 4 Desk agents. So I don't believe, if the knowledge 5 article was written correctly, then they should have 6 been able to follow that and that would have then 7 delivered the right -- the correct outcome. 8 Q. That document can come down. Thank you. 9 I've been asked to ask you if whether, to your 10 knowledge, there were members of the helpdesk who were 11 ever advised to tell subpostmasters to accept 12 discrepancies because they were caused by user error. 13 A. Absolutely not to my knowledge did that happen. 14 Q. Finally, please could we bring up statement 15 WITN06660100. This is a witness statement from Amandeep 16 Singh, who will be giving evidence to the Inquiry later 17 today and worked at the Helpdesk before your time at 18 Fujitsu in 2001, in Wakefield. Can I ask you to turn to 19 page 3, please, of the statement. I'll just read it for 20 the record. It says: 21 "The floor on these days ..." 22 When it says "these days", it is referring to 23 Wednesday when there was balancing issues: 24 "The floor on these days was most toxic with vocal 25 characters in Squad A, unchallenged by managers who 50 1 looked away as all Asians were called Patels, regardless 2 of surname. Shouts across the floor could be heard 3 saying 'I have another Patel scamming again'. They 4 mistrusted every Asian Postmaster. They mocked Scottish 5 and Welsh postmasters and pretended they could not 6 understand them. They created a picture of postmasters 7 that suggested they were incompetent or fraudsters." 8 Were you aware of any such behaviour on the Helpdesk 9 during your time at Fujitsu? 10 A. No, not at all. And reading that, I find that 11 absolutely appalling. 12 MR STEVENS: I have no further questions, but before I ask 13 if the Core Participants have questions, is there 14 anything further you would like to say to the Inquiry? 15 A. No, that's fine. Thank you. 16 MR STEVENS: Yes, Mr Stein has some questions, sir. 17 Questioned by MR STEIN 18 MR STEIN: Sir, one area of questioning, it won't take long. 19 Ms Evans-Jones, I represent a very large number of 20 subpostmasters and mistresses, all of them have been 21 affected by this scandal. Dealing with your knowledge 22 of the support systems, can you help me whether the 23 first line support groups used the same incident logging 24 system as the rest of the support chain? 25 A. Um -- 51 1 Q. Now, first of all, do you want me to repeat the 2 question? 3 A. Can you define "support chain"? Are we talking SDUs? 4 Q. Yes, well, I am quoting, in fact, from a document. It 5 is the document after your time, relating to these 6 matters. So what I'm trying to find out is whether the 7 original Horizon System had the same problem. So all 8 I've got is that the first line support groups -- so 9 I imagine are the helpline support providers. So if we 10 look at it from that perspective, did they, in your 11 time, use the same incident logging system as the rest 12 of the support chain, which would then be the lines 2, 3 13 and 4? 14 A. To the best of my knowledge, the Service Desk used 15 PowerHelp initially. That then changed to TRIOLE for 16 Services. PowerHelp, from an engineering perspective, 17 was not the system used by the engineering and it 18 transferred into a Core Services tool set that managed 19 the engineering and, to the best of my recollection, SSC 20 from the software perspective, had access to the 21 PowerHelp that they transferred it into their own tool 22 or that they worked on. 23 Q. So is the answer to my question that they didn't, in 24 fact, use -- 25 A. To the best of my knowledge, I think different systems 52 1 were used. 2 MR STEIN: Yes. Thank you. 3 SIR WYN WILLIAMS: Anyone else? 4 MS PAGE: I do have some questions, please, sir. 5 SIR WYN WILLIAMS: Yes. 6 Questioned by MS PAGE 7 MS PAGE: It's Flora Page, also representing a number of 8 subpostmasters. Can I ask, please, for document 9 FUJ00120049 to come up, please, and if we can go to 10 page 6. If we can go to the definition of -- 11 I understand this to be something which would deal with 12 problems which then go into what you've described as the 13 problem database; is that right? 14 A. Yeah, yeah. So for clarity, a problem is an issue that 15 doesn't have a documented workaround or resolution, so 16 an incident, and then you move into problem management, 17 and then change management addresses the root cause 18 that's in the problem, the kind of three flow through to 19 each other. 20 Q. Well, as I understand it from this document, the 21 relationship between an incident, which we've already 22 seen the definition of, and a problem, is that the 23 problem is defined as -- let's see if I can find it, 24 it's that second sentence of the first paragraph there: 25 "For the purpose of this document a Problem [with 53 1 a capital P] is defined as the unknown underlying root 2 cause of one or more Incidents." 3 A. Mm-hm. 4 Q. Then I think further down, it tells us -- and if you can 5 confirm it from memory, we maybe don't need to -- it was 6 three or four incidents which created a problem? 7 A. I don't think there's a specified amount of incidents 8 that would create a problem. So you could actually have 9 a problem -- this is, again, the academic theory of 10 service management. If -- any incident that you do not 11 have a resolution for or a workaround that would restore 12 service could trigger the raising of a problem, and then 13 that problem then should be investigated as to what the 14 root cause is and then that root cause should be removed 15 from the infrastructure through the change management 16 process. 17 Q. But in this document -- and perhaps we can scroll down 18 to see if we can find it -- I think it's right to say it 19 was, in fact, three or four incidents which were defined 20 as becoming a problem? 21 A. I don't know, I can't see that in the document. The 22 theory is that any one incident can generate a problem 23 and perhaps in this document it stipulates two or three. 24 I feel -- I don't see on here where it says that. 25 Q. All right, then let's just stick with one or more 54 1 incidents, then. The incident, we saw earlier, was 2 defined as "any event which is not part of the standard 3 operation of a service and which causes or may cause 4 an interruption to or a reduction in", yes? 5 A. Yes. 6 Q. All right. Can I just have look at how that translates 7 into -- falls into the system. If we could bring up, 8 please, POL00073280. If we go to page 5. Now, page 5 9 shows us what seems to be a typical record of a call in 10 to the Helpdesk; is that right? 11 A. Yes, that's what it appears to be, yes. 12 Q. Presumably this is the sort of output of the PowerHelp 13 tool; is that right? 14 A. Yeah, this is from PowerHelp, correct. 15 Q. In this particular incident, we see that it's a call in 16 on 28 January '04, we see that in the middle of the top. 17 A. Mm-hm. 18 Q. We can see there's a box called "Problem Text" about 19 halfway down, a little bit below halfway down, and this 20 is a summary of what the caller says: 21 "Caller states that discrepancies are going through 22 on the system. And this has been the case for 3 weeks 23 in a row." 24 Then it gives the amounts for the discrepancies. 25 Then we also see a little below that, two lines below 55 1 that, a text after the call has been closed and this 2 appears to be a sort of summary of why the call is 3 closed. 4 A. Mm-hm. 5 Q. It says: 6 "Call Close by Diane Meah: NBSC issue, transferred 7 for investigation." 8 So that presumably is a typical closure if the 9 caller has been referred to the NBSC? 10 A. That's my understanding from the text that's written on 11 here, yes. 12 Q. Is it right also that we would -- we then can see below 13 that, "Non-horizon Business" as the product and the 14 description, and presumably that feeds in, again, then, 15 to your metrics, does it, for how the call has been 16 resolved? 17 A. Yeah, if you refer back to the table with the graphs, 18 one of those blocks would be related to -- calls 19 classified as non-core or referred to -- I don't know 20 what the terminology is, whether they're referred to 21 NBSC or whether it's non-Horizon business. So it would 22 fall in one of those blocks on that graph that we saw. 23 Q. I think you told us, didn't you, that, from memory, you 24 didn't particularly remember discrepancies being their 25 own type of resolution? 56 1 A. Yes. No. 2 Q. But we see here an example of how a call about 3 discrepancies, is resolved as non-Horizon business, yes? 4 A. Yes, that's what this is showing. 5 Q. We don't necessarily need to go to them but there are 6 then, following this call, from the same office, which 7 is Marine Drive, it's a particular office which 8 obviously this Inquiry is going to hear a little about, 9 there are then a number of calls about discrepancies, 10 which are all basically resolved by being referred to 11 the NBSC. 12 So that is an example, is it not, of how calls about 13 discrepancies would never turn into or, in this case, 14 don't appear to have ever turned into "incidents" or 15 "problems"? 16 A. In this particular incident, yes. This wouldn't have 17 been investigated by Fujitsu. However, the comment on 18 the bottom of the screen that I can see there is that 19 the NBSC would then be able to refer that back to 20 Fujitsu following their investigation. If you recall 21 the incident flow, one of the inputs at the top would be 22 from users or from the NBSC. So this could have been 23 referred back into Fujitsu through -- and I don't know 24 if it did but this could have been referred back through 25 to Fujitsu from Post Office Account through the 57 1 processes and the engagement that we -- 2 Q. Yes, I understand. It's right. We can indeed see that 3 there is a bit of back and forth between NBSC and the 4 Horizon Helpdesk but, absent it being escalated from the 5 Horizon Helpdesk, it can't become an incident or 6 a problem? 7 A. Or have been escalated through NBSC through Post Office 8 into Fujitsu, yes. That's -- 9 Q. Yes, I see. So NBSC could escalate it straight up the 10 line, could they? 11 A. Yes. 12 MS PAGE: All right. Thank you, those are my questions. 13 A. You're welcome. 14 MR STEVENS: Sir, I think that's all of the questions from 15 the Core Participants. 16 SIR WYN WILLIAMS: Well, thank you very much for coming to 17 give evidence at the Inquiry and for providing a written 18 witness statement. I understand you may have travelled 19 from mainland Europe to give your evidence. 20 THE WITNESS: I did indeed, yes. 21 SIR WYN WILLIAMS: Yes, if that's been inconvenient for you, 22 I'm sorry. But I hope you'll combine it with something 23 which gives you some pleasure. So thank you very much. 24 THE WITNESS: Thank you very much, appreciate that. 25 MR STEVENS: Thank you, sir. If we may have a 10-minute 58 1 break for the next witness. 2 SIR WYN WILLIAMS: Yes, certainly. What is that, sorry? 3 MR STEVENS: 12.10, if we may, sir. 4 SIR WYN WILLIAMS: Yes, fine. 5 MR STEVENS: Thank you. 6 (11.57 am) 7 (A short break) 8 (12.10 pm) 9 MS KENNEDY: Good afternoon, Chair. 10 SIR WYN WILLIAMS: Good afternoon. 11 MS KENNEDY: May I call Mr Amandeep Singh, please. 12 AMANDEEP SINGH (affirmed) 13 Questioned by MS KENNEDY 14 MS KENNEDY: Mr Singh, as you know, my name is Ruth Kennedy 15 and I ask questions on behalf of the Inquiry. Could you 16 confirm your full name, please? 17 A. My name is Amandeep Singh. 18 Q. You've given a witness statement to the Inquiry. If we 19 could turn that up it's WITN06660100. Have you got that 20 witness statement in front of you? 21 A. I do, yeah. 22 Q. If you turn to page 3. Is that your signature there? 23 A. Yes, it is. 24 Q. It should be dated 13 January 2023; is that right? 25 A. That's right. 59 1 Q. Have you read through this statement recently? 2 A. Yes, I have, yes. 3 Q. Is it true to the best of your knowledge and belief? 4 A. It is, yes. 5 Q. If we could turn to paragraph 1 of that statement, so 6 scrolling down. You said you worked on the Horizon 7 Helpdesk support desk at Wakefield between September 8 October 2000 and September 2001; is that right? 9 A. That's correct. 10 Q. What was your background prior to getting that job? 11 A. So the background to the -- me getting the job was it 12 was my industrial year from university. I was studying 13 computing at Huddersfield University, and we had to 14 obtain a graduate work placement year, so the university 15 found a placement for me. I wanted to do something that 16 was a bit more hands on than what they initially found, 17 so I found a role with ICL which was going to be 18 supporting Epson Printers and I chose to take that role. 19 Q. So was this your first job? 20 A. This was my first ever full-time role, if you like, 21 yeah. I had worked part-time prior. 22 Q. When you joined, how many people were part of the 23 Horizon Helpdesk support desk? 24 A. Sorry, just to backtrack, I joined the Epson Helpdesk 25 initially and, at some point during the year, it merged 60 1 to become that -- I think ICL and Fujitsu had some type 2 of merger, and then it became -- we were all transferred 3 to the Horizon Helpdesk. Roughly, I think, there was 4 maybe six to eight teams and each team had about maybe 5 12 -- 10 to 12 members. 6 Q. Are those the squads that you were referring to in 7 paragraph 2? 8 A. Squads, yeah. 9 Q. How many squads did you say there were? 10 A. I think it may be six to eight. I'm trying to really 11 rack my brains. Between about six to eight. 12 Q. What did your role involve when you joined the Epson 13 support desk? 14 A. So my role was initially as a first line support 15 engineer. We would support all Epson printer products 16 that weren't related -- Mac related, if you like. 17 Q. How did that change when it move to the Horizon 18 Helpdesk? 19 A. So the role initially was supporting maybe technical 20 people, and -- so you'd get people in from 21 organisations, people calling in or even just generally 22 IT savvy individuals, if you like, that had issues with 23 their printer, and we would just talk them through it. 24 Sometimes there would be drivers issues or printer 25 driver -- we'd navigate them through software, how 61 1 they'd install drivers. If we couldn't then resolve 2 their issues we'd then pass them on to a second line 3 team and they would -- again, they would -- kind of more 4 specialist and a bit more -- maybe more technically able 5 than what we were in the first line team. I'm sorry, 6 the question of how it -- 7 Q. What training did you receive when you moved over to the 8 Horizon Helpdesk? 9 A. So we were all told we were going to be moving to the 10 Horizon Helpdesk. Initially, it was something that we 11 weren't aware of what we would be doing. But we got, 12 I think it was on a few days training, we got to see the 13 equipment, run some dummy transactions. We were in 14 a room where we learned how to use the software. We 15 were given a booklet on the transactions, how to 16 navigate and to do things like selling a stamp, for 17 instance, or it was routine transactions that maybe 18 a postmaster would do. And that was the level of 19 training that we received. Roughly off the top of my 20 head, I think, I got two or three days training. 21 Q. You say in your statement, if we turn to paragraph 4, so 22 over the page, that you think it was insufficient. You 23 say: 24 "The support staff faced the initial challenge of 25 basic training that was insufficient to fully support 62 1 postmasters in the full array of tasks that Horizon was 2 set up for." 3 A. Yes, I think initially it was useful because we hadn't 4 seen the software. When you're on a phone call, you 5 have to visualise what the postmaster is visualising, 6 and what the -- the transaction that they're trying to 7 do. But we were just given routine transactions. 8 I think we did one time where we had to do the 9 reconciliation task. I think we had -- off memory, 10 I think we did it once. But generally, it was how we 11 would go about doing certain transactions and that was 12 it. But we didn't really know what the calls would be 13 until we got on the call because this is really the real 14 inception of the Helpdesk itself. 15 So until the calls started coming through we didn't 16 really know what level of support we would be providing 17 postmasters, and the postmasters themselves quickly 18 picked up how to do the transactions. It wasn't 19 something they were going to struggle with but that's 20 the level of support that we would get, I think. Where 21 it was insufficient was it was the more complex 22 transactions. I think they had foreign currency 23 exchanges and how they put cheques through a system, and 24 there was things that we didn't come across originally. 25 So, again, it was learning on the job, and a lot of 63 1 it was just trying to remember, look at your booklets 2 and guiding a customer -- guiding the postmaster through 3 certain transactions, and it was generally at that 4 level. 5 That's what I meant by insufficient. It wasn't more 6 than just routine transactions, which is what the 7 Helpdesk training was really all about. 8 Q. How many calls were you fielding from subpostmasters? 9 A. It felt, initially at the start, we were sort of 10 inundated really, to be fair. So there were -- just 11 a constant stream of calls tend to come. They did used 12 to obviously peak on Wednesdays but it was a steady flow 13 of calls constantly. 14 Q. Why did they peak on Wednesday? 15 A. That was their reconciliation day, so that's when 16 postmasters would then do their -- if you like, they'd 17 balance the books, as such. 18 Q. Can you describe what that day was like, from your 19 perspective? 20 A. We would generally come in later because -- we had 21 different shifts, to be fair. So there'd be the normal 22 shifts that were covering -- they'd finish around 5.00 23 but you'd always have certain teams that would have to 24 stay longer because we kept the desk, as far as I can 25 remember, open for longer that day because you knew it 64 1 was going to be a really heavy, heavy day. You could be 2 on a call with a postmaster for a few hours trying to 3 help them to reconcile, and that was very stressful 4 days. 5 Q. You say at paragraph 5 of your statement you'd gone from 6 dealing with IT savvy people, essentially, to people who 7 had never owned a machine before and weren't computer 8 literate; is that right? 9 A. Yeah, that's right. I mean, like I said, this was early 10 2000s. A lot of postmasters had worked in their -- you 11 know, in their branches for decades, in some cases, and 12 they'd never been around even a personal computer. So 13 it was not only introducing, you know, personal 14 computing into their lives, really, in some cases for 15 the first time, but it was then also giving them 16 exposure to "Here, now use this software". And some of 17 them wouldn't -- you'd have to explain to them what the 18 mouse was, in some cases. 19 I mean they wouldn't know what you meant by a mouse. 20 I mean, it's literally this is the age, the time we were 21 dealing with -- with certain people. Not everybody, but 22 a lot of postmasters were elderly. Some of them -- 23 I mean, a lot of them weren't IT literate at all. 24 I mean, generally the public, you could say at that 25 time, not many of them were either. 65 1 But -- and that brought its anxiety and stress to 2 postmasters themselves and as well as to us, because we 3 had to explain sometimes maybe a complex transaction, 4 but knowing that they themselves were not very literate 5 in terms of just orientating themselves around the 6 screen, trying to pick the right transactions, the right 7 icons, and you'd have to describe the icon on the screen 8 in detail. Go "Yes, press that. Now you're seeing 9 another screen". And so it was really -- trying to 10 guide them as much as you could, and that itself did 11 bring a level of stress because you were constantly 12 aware that other calls were coming through, there was 13 a backlog of calls, and you knew that that the call 14 started somewhere but it would end somewhere. And it 15 was trying to get them to that resolution point and 16 sometimes you would just feel a bit deflated in terms of 17 how can I get this person to that endpoint when they're 18 not really capable of sometimes getting there? 19 Q. What training, if any, did you receive in how to deal 20 with people of different computer literacies? 21 A. Nothing. 22 Q. Were there any particular types of problems that you 23 were asked to be ready for, or examples of issues that 24 subpostmasters may face that you were trained on? 25 A. No, not that I can recall. 66 1 Q. At paragraph 6 of your statement, you say that the floor 2 was quite a toxic place. Could you tell us a bit about 3 more about what you mean by that? 4 A. Just to elaborate on the point that I've made about the 5 postmasters themselves. So, for me, this was my very 6 first IT role so I was -- dealing with people that were 7 ringing in and wanting the help on their printers were 8 generally people that tended to know about -- you know, 9 at the time it was Windows 95 or Windows 98 and you'd 10 "You can install a driver?" "Have you checked this?" 11 You know, how to run a clean cycle on a printer. All of 12 this terminology, in many cases, was just over the head 13 of a lot of post -- you know ... 14 And for me it was a learning curve because it was, 15 without being too crude, it was a job and I thought 16 "Well, I'm a uni student, I'm going to go back to uni, 17 I'm just going to see this out and see this is what the 18 world like". But it was toxic because the other members 19 of staff that were, if you like, the second line team, 20 the whole second line team had been abandoned and 21 everybody had just merged into this Horizon Helpdesk. 22 So there was a hierarchy of the second line team -- 23 so we would never interact with, as first line engineers 24 on the Epson team, because we really, some of them, we 25 would hate having to put calls through to them because 67 1 they would almost belittle you in some way when you 2 would pass a call to them. Like "Can you not deal with 3 this yourself?" There was a hierarchy of individuals, 4 to say we are really talented in engineers. They hated 5 us passing calls through to them. 6 So there was that dynamic where you didn't really 7 associate with those guys well. And then when they were 8 all brought in, everybody was equalised and on the same 9 level, that caused a great deal of animosity. And then 10 layer on top of that, you're now not supporting maybe 11 graphic design agencies or media companies as second 12 line engineers were doing, and now you're supporting, 13 you know, an old lady in Wales that doesn't know what 14 even a personal computer is. 15 It felt, I think a lot of them felt like the role 16 was beneath them, and that animosity, that toxicity, it 17 just grew and grew. And people were -- it became a bit 18 like people were almost on the calls and they were 19 almost shouting about "Oh my God, I've got this person 20 on a call", and this -- and it became almost comical to 21 watch people frustrated and throwing their arms about 22 and making a scene about supporting somebody who can't 23 do. And obviously they weren't projecting it to the 24 customer because it were going on mute, throwing their 25 arms up, "Oh look at this person, I can't believe I have 68 1 got this, they don't know this, they don't know that", 2 and you'd get had a lot from the members of staff that 3 were, you know, the second line engineers, if you like. 4 And it just created an atmosphere that were just -- 5 you didn't really want to be there. The people and the 6 teams didn't want to be there, and, like I said, it were 7 just going through -- for me, just going through the 8 motions of getting through each day. 9 Q. If we turn over the page, still in paragraph 6, you 10 mentioned some of the comments that you heard while you 11 were there. Do you want to tell us a bit about that? 12 A. Yeah, because I wanted -- the reason why I got in 13 contact with the Inquiry itself was because it felt 14 a little bit like -- I don't know how much that the -- 15 it was going to be an inquiry about senior management or 16 maybe people looking away or people from top-down 17 dictating practices or something, and I wanted to just 18 give you my real-world experience of what it was like 19 just on the Helpdesk on the floor. 20 It wasn't like this Big Brother element of senior 21 management, just my opinions of day-to-day of what it 22 was like. And what I wanted to get across was you had 23 that element of where you had the teams merging into 24 one, supporting the postmasters, that resentment towards 25 the role, that they'd been now forced to take on. And 69 1 then you had another layer upon that, with the cultural 2 issues in some cases. Many of these people were 3 supporting -- Asian postmasters, not to put it in any 4 blunter terms than that, but sometimes an Asian 5 postmaster they would ring up and they'd be it like 6 "I've got a £2,000 discrepancy, I've got a £5,000 7 discrepancy", in some cases you'd get wild figures like 8 50,000 or 100,000 and sometimes these figures, people 9 were quoting were more than most of the salaries, annual 10 salaries of the individuals that they were supporting. 11 And if you like, so if you layer upon that, they're 12 doing a job they don't want to do, then someone rings up 13 and says £15,000 is missing from my account, and people 14 were like "Oh, here's another one calling". 15 And you'd get so many of these calls, not just from 16 Asian subpostmasters but from everywhere, all walks from 17 the UK, people would be calling in and they'd be saying 18 these figures and it's more than, you know, a monthly 19 salary, more than an annual salary of a lot of 20 individuals and they'd think "Where's this money gone?" 21 And it just build that mistrust. 22 And I think at the time, there was always stories in 23 the newspapers of somebody maybe frauding or defrauding 24 or doing something. And if somebody rings you up and 25 says £50,000 or £10,000 is missing, and you'd be like -- 70 1 even -- you know, you'd question it and say, "How can 2 you miscalculate 10,000 or 2,000?" It's not a couple of 3 stamps here or there. You can't reconcile to £20 or 4 £30. But these were huge figures that people were 5 quoting. 6 But -- and I think that's what I meant. Once that 7 story got about, once somebody said, "Oh, I've got 8 another Patel", and then you could just never get away 9 from that whole "Patel" thing. And it would be like who 10 could come up with the most outlandish story, "Oh, I've 11 got a Patel, got another Patel", you'd just hear it 12 constantly on the floor and me obviously being from 13 an Asian background, there was me and another gentleman 14 called Zubair we were the only two ethnic minorities on 15 the support desk at all, on the whole entire floor. 16 There was a Chinese gentleman or someone from a Chinese 17 background, Peter, and they were the only people of sort 18 of colour on that floor. 19 And at no point was anybody reeling it back and 20 saying, "What is this -- you know, the language that was 21 being used?" And my grievance with it was that it was 22 a case of why don't we just focus on the individual or 23 the actual -- this cultural dynamic, this mistrust, that 24 was just feeding through. It felt like some individuals 25 could never get beyond that, could never look beyond 71 1 that and try and do the role they were instructed to do. 2 And this is one of the prime reasons that I wanted 3 to, you know, get in touch with the Helpdesk itself. 4 Q. How did that make you feel, working in this environment? 5 A. I told myself every day that I'm here just for the year 6 and I'm just seeing it, and I was paid almost twice as 7 much as nearly all the other graduates that I knew, so 8 I knew that I was well paid. And, for me, I thought 9 "It's okay", and speaking with -- from Indian parents, 10 to be fair, my parents, my mum and dad go "This is just 11 work, this is what it's like in the outside world", you 12 would just get told -- and that was really depressing, 13 to be fair, to be told that. And I just thought "Wow, 14 I've got a whole lifetime of this ahead me and this is 15 what it's going to be like so I'd better just get used 16 to it". And I'd just go into work and be just like 17 okay. 18 And nobody ever said anything racial to me, I would 19 just fit in with the team. I was with the most vocal 20 team, which was Squad A. But nobody ever said anything 21 personal to me, I fit in and I could hold my own, I'm 22 quite thick skinned, I grew up in that environment, so 23 it wasn't difficult for me in many ways in such as 24 I look back now, as somebody who has been and worked in 25 the industry for almost 20 years and look back and 72 1 think -- you know, now having two boys and having young 2 kids thinking how difficult I would feel if they were in 3 that environment. 4 But me personally, I think I just find it harder now 5 to look back than I did then, whereas -- when it was 6 just a case of: let's just get through the day. It's 7 another day. I'm earning good money. Let's just move 8 on. And that's what it was. But it was difficult. 9 I did know that a lot of conversations were going 10 on, and it was a case of when I would walk into a room 11 sometimes it would go quiet, and I knew some things 12 wanted to be said by certain individuals. So I would 13 almost make an excuse to leave to let them complete 14 their conversation and then go back, because I know that 15 they wanted to say something. And it was a case of 16 managing that environment, for me. But I really took it 17 as a point of: this is something that I've got to go 18 through and learn. And that was really sort of how 19 I navigated my days, really. 20 Q. Turning back to your statement, if we look at 21 paragraph 7, you say: 22 "As for their reconciling issues [the 23 subpostmasters], when we could not help them with their 24 accounts, this would mean we spent a few hours on the 25 phone going through each transaction and trying to 73 1 figure out where the financial discrepancy was. We 2 would eventually give up, and we were advised to write 3 off the loss as a 'discrepancy'. This was a word you 4 could hear from every agent's calls." 5 Do you want to elaborate a bit more on your 6 experience with this? 7 A. Yes, and just to caveat what I'm saying, I did feel that 8 every agent, no matter what they said, they did try 9 their best to try to get -- to try to help every 10 postmaster that, you know, they called up. But the 11 Wednesdays days, you would -- and bearing in mind that 12 none of us were from an accountancy background, we were 13 just IT people, but we would almost be bookkeeping live 14 with an individual for an entire week's transactions 15 trying to get down where did they get this discrepancy 16 from. So it would be if you like how many stamps did 17 they sell? How many foreign currency transactions? So 18 these are the transactions, that's what you're supposed 19 to have. We would go line by line through every single 20 transaction trying to understand where did this 21 discrepancy come from. That's why the call would take 22 hours. This is why you had to almost, you know, 23 physically build yourself up sometimes for calls when 24 you knew, when somebody would call and go they've got 25 a discrepancy for a few thousand. And you know right, 74 1 okay, this is going to be a difficult one. And you'd go 2 through all these transactions. 3 And the postmasters themselves were always quite 4 frantic. They were, you know, they were so stressed. 5 "How do I get this? How have I got this figure? How am 6 I going to reconcile this account?" 7 And so, you know, we would work with them for hours. 8 We would really try our best to get down to it. And 9 then, you know, we couldn't resolve it. We'd go to -- 10 we'd have a team leader, sometimes floor walkers, and 11 ask their opinions, "Have you checked this? Have you 12 checked that?" We'd go back and try and resolve it, and 13 if we couldn't, it would be like okay, it's 14 a discrepancy. Write it off as a discrepancy. We can't 15 really do anything more beyond that. And it just almost 16 became the norm, in a way. And you'd have postmasters 17 did say, "I had one last week, I was like" -- someone 18 had £46, it was small figures. They'd be like, "I will 19 put money in myself, just to circle it. Just to square 20 the circle, if you like, just to get it to a zero 21 balance." They'd be like, "I've been doing it now for 22 weeks." 23 And it was only when they got these extreme figures, 24 these big figures, that they would call in. And then 25 you'd find that that's when they'd need help. Sometimes 75 1 when they were small figures they'd tell you, "Oh we've 2 been putting money in ourselves just to get it to zero." 3 Like I said, you could just hear the word 4 "discrepancy". It was probably the most used word, as 5 well, on every call. "Oh, have you got a discrepancy?" 6 Like I said, it quickly went from "How do I do this 7 transaction?" After a few months, people knew all the 8 transactions. "How do I reconcile them?" Then nearly 9 everything was just discrepancy, discrepancy, 10 discrepancy. That's what the calls were really about. 11 People just not being able to, you know, reconcile their 12 accounts to zero. 13 Q. When you say, "We were advised to write off the loss as 14 a discrepancy", who was advising you? 15 A. So now, I really tried to rack my brains on this one 16 because we -- because there was a -- we had a management 17 team that were in the helpdesk. They were in the sort 18 of -- the way that the helpdesk was located, you had the 19 managers that would sit in the middle of the helpdesk. 20 And I was trying to rack my brains and think who was 21 telling me? And I remember it was -- sometimes it would 22 be, like, just one of the people in our team that were 23 the most able on the software. And you'd 24 cross-reference it with some of your colleagues. And 25 then I think they'd put in some team leaders type in 76 1 place, because the managers themselves, they didn't know 2 nothing. They never touched the software. They didn't 3 do any training. You'd only go to your managers if you 4 wanted to get a holiday. You'd go to them and go, "Can 5 I have a holiday booked?" 6 And then managers were acutely aware that the floor 7 was struggling, so they almost strategically picked out 8 people out of each squad that were the most able on the 9 software, and sort of made them like floor walkers or 10 team leaders or advocates, if you like. And you'd go to 11 them and say: "Right, okay, I'm struggling." 12 And they would go, "Well, there's nothing we can do. 13 This is a discrepancy." 14 And that was it. It was never the managers. 15 I mean, like I say, other than signing holidays, I don't 16 know what they did. They weren't -- like these days, if 17 you look at call centres, you have people listening in 18 to calls, reviewing calls. In the year that I was 19 there, I honestly can't tell you what they did other 20 than sign our holidays -- you know, sign off holidays, 21 or we'd ask them for that. And there were a good few of 22 them. There were a good five of them -- five, six, 23 seven of them. 24 And it was a gripe that most of the engineers had as 25 well: that what is their role? What do they do? 77 1 Because we needed help, we needed guidance, and we 2 didn't really get it. So it was your colleagues. To 3 answer your question, it was kind of your colleagues, 4 and then the floor walkers which were normally -- which 5 were, again, your colleagues that you'd go to. So there 6 wasn't anyone in a senior or a management role that 7 you'd told. And that was again one of the reasons why 8 I wanted to contact the -- because rather than saying it 9 was some sort of mythical big bad manager who was 10 telling you whatever, or guiding you, in the very 11 initial year that I was there when it was set up, it 12 felt very much like a rudderless ship, really, and you 13 were just guided somehow on your own. 14 And I think -- it probably stems from all the other 15 issues I raised -- just the lack of management in that 16 interaction across the floor. 17 Q. Do you think genuine issues with Horizon were missed 18 because of the toxic culture? 19 A. Being there only a year, it's very difficult to ask that 20 question. To answer that question, sorry. I think it 21 didn't help, it really didn't help, because if people 22 were genuine having software issues, but if you've 23 already got a pre-built prejudice that you can't trust 24 the people or the people are incompetent -- and that's 25 really, like I said, the nub of the issue for me -- is 78 1 if you've already made a judgement call on the people 2 that you're supporting as incompetent or corrupt in some 3 way, it would take a lot of people to go, you know, that 4 the software has an issue. 5 Because I think people were -- we were much happier, 6 on the floor, to push down on to the postmasters and go 7 "This is your issue", or "You're not correct", or 8 "You've got the issues", than anyone on the floor 9 going -- pushing this upwards and going, "Is this is an 10 issue here? How can we have so many of these calls?" 11 Like I said, we didn't know who to push up to. And the 12 management were just not visible. Like I said, I just 13 don't know what they did. 14 So you can see it must have taken almost like 15 a snowball effect on -- for someone just to look into 16 this issue to go: "Surely we can't have this many 17 discrepancies?" So you can see how it must have just 18 snowballed. And like I said, I was only there for 19 a year, and maybe it just grew and grew, and then 20 eventually, you know, just through the number of issues 21 and discrepancies, that's how it must have got through. 22 But I don't think the people's, you know, pre-built 23 prejudices, I don't think they helped at all because 24 they could never empathise with the postmasters. They 25 could never understand their issues. Even when they 79 1 were upset and crying on the phones -- which we had all 2 the time. Really upset individuals trying to 3 understand, trying to, you know, get their accounts to 4 zero. But I think it's difficult. It's very simplistic 5 to just say that. I think there was other issues 6 involved, but I don't think it helped. 7 Q. Is there anything else you wanted to say about your 8 experiences to the Inquiry? 9 A. Um, like I said, they would be more personal on me in 10 terms of how I felt as an individual, and I don't want 11 it to blur the fact that this is an issue about 12 postmasters and basically about the Post Office itself, 13 or -- and, you know, their own issues as opposed to how 14 I really felt. I think just -- to me, it was a lot of 15 issues at the time, just a lot of issues of just, like, 16 the postmasters, their technical capabilities, a lack of 17 absence of management, of people. And, you know, I know 18 that now they've got like first, second line teams and 19 problem management and change management, and all this. 20 When I was there, they had just that one team. It was 21 immature. Now I can look back after 20 years in the IT 22 industry, I can look back and see just the people 23 themselves, the managers were not qualified to do the 24 job. The individuals, some of them, should never have 25 been supportive. 80 1 It looks just, you know, with hindsight -- and it's 2 easy with hindsight to say these things -- but there 3 were just culpability on so many levels, on so many 4 areas. And it's probably good to have this, the review, 5 to look, just from an organisational point of view, of 6 how these structures, when they're not there, that's how 7 issues like these can arise. When you don't have the 8 change management, when you don't have the problem 9 management, when you don't have analysis. And we didn't 10 have much of that stuff going on, and we had an absence 11 of management, of people not probing in to look as to 12 why there are issues. 13 You know, this is why, you know, since then, you 14 have this ITIL standards or the Service Desk. You just 15 have things that didn't exist at the time. 16 MS KENNEDY: Thank you, Mr Singh. I don't have any more 17 questions for you. Mr Stein has a question. 18 Questioned by MR STEIN 19 MR STEIN: Mr Singh, I represent a large number of 20 postmasters and mistresses. Can we just describe, 21 please, the area where you worked so that the Inquiry 22 can grasp whether you worked in booths or whether you 23 worked in a large, open-floor space. Could you just 24 describe the area you worked? 25 A. It was the large -- a large area. We had our own desks 81 1 but they were segregated slightly by the squads that you 2 worked in. So you sat with your squad, but it was very 3 much an open desk. There weren't private booths. So it 4 was very much open. 5 Q. So if somebody is shouting out from your squad, would 6 another squad be able to hear that, across the floor? 7 A. Yes. 8 Q. You mentioned the floor walker system, and you've also 9 spoken about managers. In your statement, you say this: 10 that when people were being vocal and toxic in what 11 they're saying, that they were unchallenged by managers. 12 And I quote from your statement that they looked away 13 the managers looked away, "as all Asians were called 14 Patels, regardless of surname." 15 A. Mm-hm. 16 Q. Did you ever see a manager discuss the behaviour of the 17 individuals who spoke in that way? 18 A. No. And I now, being obviously 44 years old and not 19 someone who was like 21 at the time, I would challenge 20 that. But then I think these days it's very rare you 21 would need to challenge that sort of behaviour. But at 22 the time, there were some very strong-willed characters 23 there who had almost, you know, roughshod -- they could 24 ride roughshod over whatever they wanted to say. But it 25 was a case: "Oh, he's a character. Oh, they're 82 1 characters." And we just let them go. We would just 2 leave them to it, if you like. 3 They never challenged them but then, like I said, 4 other than signing our, you know, holidays -- asking for 5 holiday, I don't think they did anything, those 6 managers. I look back now and think, you know, the 7 bureaucracy that must have existed to have so many 8 managers which then led on to other managers, and then 9 neither of them, you couldn't really define what their 10 role actually was. 11 Q. Two last points. Do you by any chance remember the name 12 of the manager that you were directly dealing with? Was 13 there a single individual that you would have described 14 as being your manager? And if so, can you remember 15 their name? 16 A. I can remember their name. So mine would have been 17 Geraldine McEwan, I think it would have been. 18 Q. Thank you. Lastly, then, you've said that you don't 19 want to confuse issues between the effect on you versus 20 what was happening to the subpostmasters and mistresses. 21 Was the effect upon you, what you were going through in 22 that period of time, was that something that inhibited 23 or stopped you from, as an example, trying to take it 24 any further within the organisation? 25 A. Um, taking it further was never a thought in my mind. 83 1 I'm going to be bluntly honest with you. I couldn't 2 wait to get out of that role quick enough, and I did see 3 it as the fact that this is a rite of passage for me. 4 It's something like coming of age, doing my role, doing 5 my time. And the best way to describe it is like if 6 you're in prison and you've got the tally charts and you 7 are crossing the days off to go: right, I'm going to 8 leave on that day. And like I said, I was well paid. 9 And I didn't want people to think that it affected me, 10 the language, as well, on the floor. So I didn't want 11 anyone to think that I'm just weak, in some ways, or 12 that I've got an issue with it, or I've got a chip on my 13 shoulder, or this language, or -- it was easier for me 14 to just go: let's just see it through. It's fine. 15 One thing I do want to mention is that it's very 16 much an issue of I feel, having worked at, like I say, 17 predominantly within the south, within London, within 18 the banking industry, that it's, to me, it was very much 19 a cultural issue of Yorkshire, Wakefield, of communities 20 that don't mix and are mistrusting of each other. 21 And this is why I wanted to raise the issue of this 22 why people that were hiring, the incompetence level of 23 it. If you're supporting people from Wales and villages 24 in Wales and in Scotland, and there predominantly is 25 a lot of Asian people owning post offices, is for you to 84 1 understand the people, as well, that you're going to be 2 supporting. And, you know, be able to put yourself in 3 their shoes or walk, you know, in effect walk in their 4 shoes and understand their life situations. And the 5 people that they were, having supported them, could 6 never do that, and are almost incapable of doing that. 7 And I think that's one of the issues that I wanted to 8 sort of raise as well. 9 MR STEIN: Thank you, Mr Singh. 10 THE WITNESS: Thank you. 11 MS KENNEDY: Chair, I don't think there are any further 12 questions from any further Core Participants. 13 SIR WYN WILLIAMS: All right. 14 Well, Mr Singh, I'm very grateful to you for drawing 15 these matters to my attention and for making contact 16 with the Inquiry, and being determined to give oral 17 evidence about these things. So thank you very much. 18 THE WITNESS: Thank you. 19 MS KENNEDY: Chair, that concludes the witness evidence for 20 today. We're back tomorrow with Mr Andrew Dunks. 21 SIR WYN WILLIAMS: Yes, fine. All right, then. 10.00 22 tomorrow. 23 MS KENNEDY: Thank you. 24 (12.46 pm) 25 (The hearing adjourned until 10.00 am the following day) 85 I N D E X ELIZABETH JANE EVANS-JONES ...........................1 (affirmed) Questioned by MR STEVENS ......................1 Questioned by MR STEIN .......................51 Questioned by MS PAGE ........................53 AMANDEEP SINGH (affirmed) ...........................59 Questioned by MS KENNEDY .....................59 Questioned by MR STEIN .......................81 86