This is cribbed from the appendix of the defendant's opening statement to the Horizon trial. They are the issues the judge, Sir Peter Fraser, will have to decide on:
Please note the defendant's appendix says: ""the Horizon System" shall for the purposes of this list of issues mean the Horizon computer system hardware and software, communications equipment in branch and central data centres where records of transactions made in branch were processed."
Now here we go:
Bugs, Errors and Defects in Horizon
Accuracy and integrity of data
(1) To what extent was it possible or likely for bugs, errors or defects to have the potential to:
(a) cause apparent or alleged discrepancies or shortfalls relating to Subpostmasters' branch accounts or transactions, or
(b) undermine the reliability of Horizon accurately to process and to record transactions.
(2) Did the Horizon IT system itself alert Subpostmasters of such bugs, errors or defects as described in (1) above and if so how.
(3) To what extent and in what respects is the Horizon System "robust" and extremely unlikely to be the cause of shortfalls in branches?
Controls and measures for preventing / fixing bugs and developing the system
(4) To what extent has there been potential for errors in data recorded within Horizon to arise in
(a) data entry,
(b) transfer or
(c) processing of data in Horizon?
(5) How, if at all, does the Horizon system itself compare transaction data recorded by Horizon against transaction data from sources outside of Horizon?
(6) To what extent did measures and/or controls that existed in Horizon prevent, detect, identify, report or reduce to an extremely low level the risk of the
following:
(a) data entry errors;
(b) data packet or system level errors (including data processing, effecting, and recording the same);
(c) a failure to detect, correct and remedy software coding errors or bugs;
(d) errors in the transmission, replication and storage of transaction record data; and
(e) the data stored in the central data centre not being an accurate record of transactions entered on branch terminals?
Operation of Horizon
Remote Access
(7) Were Post Office and/or Fujitsu able to access transaction data recorded by Horizon remotely (i.e. not from within a branch)?
Availability of Information and Report Writing
(8) What transaction data and reporting functions were available through Horizon to Post Office for identifying the occurrence of alleged shortfalls and the causes of alleged shortfalls in branches, including whether they were caused by bugs, errors and/or defects in the Horizon system?
(9) At all material times, what transaction data and reporting functions (if any) were available through Horizon to Subpostmasters for:
(a) identifying apparent or alleged discrepancies and shortfalls and/or the causes of the same; and
(b) accessing and identifying transactions recorded on Horizon?
Access to and/or Editing of Transactions and Branch Accounts
(10) Whether the Defendant and/or Fujitsu have had the ability/facility to:
(i) insert, inject, edit or delete transaction data or data in branch accounts;
(ii) implement fixes in Horizon that had the potential to affect transaction data or data in branch accounts; or
(iii) rebuild branch transaction data:
(a) at all;
(b) without the knowledge of the Subpostmaster in question; and
(c) without the consent of the Subpostmaster in question.
(11) If they did, did the Horizon system have any permission controls upon the use of the above facility, and did the system maintain a log of such actions and such permission controls?
(12) If the Defendant and/or Fujitsu did have such ability, how often was that used, if at all?
(13) To what extent did use of any such facility have the potential to affect the reliability of Branches' accounting positions?
Branch trading statements, making good and disputing shortfalls
(14) How (if at all) does the Horizon system and its functionality:
(a) enable Subpostmasters to compare the stock and cash in a branch against the stock and cash indicated on Horizon?
(b) enable or require Subpostmasters to decide how to deal with, dispute, accept or make good an alleged discrepancy by:
(i) providing his or her own personal funds or
(ii) settling centrally?
(c) record and reflect the consequence of raising a dispute on an alleged discrepancy, on Horizon Branch account data and, in particular:
(iii) does raising a dispute with the Helpline cause a block to be placed on the value of an alleged shortfall; and
(iv) is that recorded on the Horizon system as a debt due to Post Office?
(e) enable Subpostmasters to produce:
(i) Cash Account before 2005 and
(ii) Branch Trading Statement after 2005?
(f) enable or require Subpostmasters to continue to trade if they did not complete a Branch Trading Statement; and, if so, on what basis and with what consequences on the Horizon system?
Transaction Corrections
(15) How did Horizon process and/or record Transaction Corrections?
ENDS. That's your lot.
ENDS. That's your lot.
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