Home Affairs Committee - Minutes of EvidenceHC 100

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Oral Evidence

Taken before the Home Affairs Committee

on Tuesday 13 March 2012

Members present:

Keith Vaz (Chair)

Nicola Blackwood

Mr James Clappison

Michael Ellis

Lorraine Fullbrook

Steve McCabe

Alun Michael

Mr David Winnick

________________

Examination of Witnesses

Witnesses: Tommy Helsby, Chairman, Kroll, John Conyngham, Group General Counsel and Global Director, Corporate Investigations, Control Risks, and Bill Waite, Chief Executive Officer, Risk Advisory Group, gave evidence.

Q146 Chair: Mr Conyngham, Mr Waite and Mr Helsby, thank you very much for coming. This is the latest session in the Committee’s ongoing inquiry into private investigators. We are most grateful to all of you for coming, representing Kroll, Control Risks and the Risk Advisory Group, three of the largest investigation companies in this country. When there are three witnesses, it is always difficult to know when to come in. Please feel free to chip in to any of the questions that my colleagues and I ask of you. The only thing is we would very much like brief and succinct answers because we have other witnesses on other inquiries coming in after you. We will also try to ask brief and succinct questions of you.

Can I begin with you, Mr Helsby, and the others perhaps would like to comment. There appears to be a lot of concern about the way in which your industry is-I was going to say regulated, but not regulated may be better. Is that concern shared by the three of you? Mr Helsby, perhaps you can start.

Tommy Helsby: We do have a concern about the lack of regulation, principally because of the public image problem that it creates for what is loosely described as an industry. Private investigation, outside of novels, is a fairly broad and ill-defined activity. What I do and what my friends here do is a commercial activity driven by business needs, and has nothing to do with the kind of issues that have emerged in the press and given rise to the concerns over the past year.

Q147 Chair: Thank you. Mr Waite?

Bill Waite: We have supported regulation of the private security industry in terms of the core competencies that were outlined in the 2007 paper-that is, around issues such as formal investigations, surveillance and physical monitoring of individuals. We co-operated in 2003, 2006 and 2007 with the SIA to try to get some texture around what that regulation might look like.

Q148 Chair: Mr Conyngham?

John Conyngham: We, too, have supported regulation from the very beginning. Our concern is the same as Kroll’s, as Tommy Helsby has just explained: the image that the activities we have been reading about in the press every day over the last months are giving to this industry, and perhaps our failure to explain properly what, in our part of this sector, we are doing and how important that has become. I think we have seen in our industry how we have gone over the last 15 years from, on the due diligence side of affairs, perhaps being an optional extra, to being now a mainstream advisor: many pieces of legislation-the latest being the Bribery Act-are coming out, and we are telling companies how they must know who they employ, who they do business with and on what terms they do business. That is a very large part of what we do. There are other parts-the more intrusive parts of investigation, in relation to fraud investigation or malfeasance-where there is a need for regulation and there should be regulation, and we are regulated elsewhere for those purposes, in other jurisdictions. But we would like to maybe have a discussion this morning about the area of due diligence.

Q149 Chair: Yes. You are all quite clear. You seem to be distancing yourselves from the examples that the public has seen and Parliament has seen about illegality within the private investigation industry. You are quite clear that as far as your three firms are concerned there is no question of anyone involving themselves in illegality in the work that they do?

Bill Waite: That is quite right. We go to great lengths in our internal training protocols to ensure that people within the firm have a deep and detailed understanding of the relevant legislation. Indeed, we made that recommendation to the SIA when it was looking at competencies. We have FSA-level screening of our staff to ensure that they are essentially fit and proper to do what they do, and we support their skills and experience by additional training as and when required. But you have to understand that we work for governments, government departments, multinational and multilateral organisations, and our businesses are all significant businesses. We could not afford, apart from any other issue, to be involved in any activity that caused any kind of stigma to attach to our clients, or indeed to us.

John Conyngham: In Control Risks, investigations is by far not the only thing we do. We do many other activities. Indeed, investigations was, in effect, the last core area that the company got into-I was invited in 1994 to set up the investigations side. The company could have been in this area a lot earlier but it had concerns about possible reputational issues, how we would define an investigation, and how we could even guarantee the outcome of an investigation. We started up at Control Risks with a very clear mandate that this was to be internally highly regulated, with standard operating procedures and codes of conduct, and it has been from the very beginning. We read about what everybody else is reading about, but only with mild interest because it doesn’t affect our business.

Q150 Chair: Mr Helsby?

Tommy Helsby: Kroll is a little different from the other two companies in the sense that we are an American-owned company and as such, we are licensed as investigators in 50 states in the US. We also have licences in Italy, in Spain, in Japan and, I think, in Singapore. We spent the last 12 years first as an independent public company and then as part of a much bigger public company-we are now private-equity owned-so we were subject to SEC regulation, to Sarbanes-Oxley-

Q151 Chair: So you think the American system is better than the system we have here?

Tommy Helsby: No. What I would say is that the regulation of investigative activity is a good thing as long as it is done in an efficient and proportionate manner, partly because, as I said at the beginning, we would like to raise the reputation of the industry. We would like people to think of what we do as a good thing and something that is on the right side of public policy. We know it is, but there are some people who do not operate by the same rules.

Q152 Chair: Do you think these people are dragging the good name of the industry down?

Tommy Helsby: Along with novelists.

Q153 Chair: Can I just ask you about police officers and the relationship you have with the police, but first, very quickly, will you tell us about your backgrounds-your careers before you took on your present career? What were you doing, Mr Helsby?

Tommy Helsby: I have worked for Kroll for 31 years, so I can barely remember. I was briefly a writer and before that I was doing a PhD.

Q154 Chair: Mr Waite?

Bill Waite: I spent seven years at the Bar, principally defending in criminal cases. I was then seconded to the Serious Fraud Office for three and a half years. I was on the way back to the Bar, but I was headhunted, actually by Kroll Associates. I left Kroll after two and a half years, raised venture capital and started the Risk Advisory Group 15 years ago.

Q155 Chair: Mr Conyngham?

John Conyngham: I qualified at the Bar in 1975 and initially worked for Her Majesty’s Customs and Excise. Then I moved to Hong Kong, where for 10 years I was a prosecutor in the Attorney General’s Chambers, specialising in fraud prosecution. I came back from Hong Kong in 1989 and went to Kroll Associates and set up the legal function there and the fraud function, and I have been at Control Risks since 1994.

Q156 Chair: Thank you. We were surprised at the number of former police officers who worked for private investigation firms. Do you have any figures for us as to the number of employees of yours who were formerly police officers?

John Conyngham: A very small minority. Out of a team of 50 sitting in our London office, we have three with police backgrounds, and I think that is what is interesting. If I could just briefly refer to some of the backgrounds of the people that we have, I am looking here at someone-I happen to know it is a female-who has a first-class degree and MPhil, both in philosophy, from Cambridge University; a Spanish national with a PhD in Russian politics from the School of Slavonic and East European Studies; a person based in Dubai with a master’s degree in Middle Eastern-

Q157 Chair: Are these the police officers?

John Conyngham: These are not the police officers.

Chair: These are the others?

John Conyngham: These are all the other people. The police officers are one former inspector and a high profile ex-policeman, Ken Farrow, who was head of the Economic Crime Unit at the City of London Police until about six years ago.

Q158 Chair: Mr Waite?

Bill Waite: We have none.

Q159 Chair: None? Not a single former police officer works for your company?

Bill Waite: Not a single former police officer works for my company.

Q160 Chair: Mr Helsby?

Tommy Helsby: Among the various businesses under the Kroll banner in the UK we have a little over 400 employees. One of them is a former police officer.

Q161 Mr Clappison: Can I ask you if you regard your companies as private investigation companies? Perhaps start with Mr Waite.

Bill Waite: We have a number of different offerings. We have an employee screening business, we have a political risk and security business, we have a transactional due diligence business and we have an investigations business, which falls within those competence areas that I was talking about. It conducts formal interviews, and sometimes physical and electronic surveillance.

Q162 Mr Clappison: So you would regard yourself as a private investigation-

Bill Waite: No, I would regard our firm as a global risk management consultancy.

Q163 Mr Clappison: All right, global risk management. Would you gentlemen give a similar answer?

Tommy Helsby: I think a significant part of what we do is investigations. I tend to describe it as corporate investigations because it would be extremely unusual for us to be engaged outside of the business context.

Q164 Mr Clappison: So it is more George Smiley than Columbo sort of thing?

Tommy Helsby: It is not George Smiley either. It is less exciting than that, I’m afraid.

Bill Waite: I think you have to realise that for a long period of time now, there has been a lack of resource in Government and Government Departments, including areas such as the police force. There was an initiative in 2001 called the Partnership Against Crime, when three of our firms were accredited as investigators to help support the police function in conducting internal investigations for corporates because the police resource wasn’t there.

Q165 Mr Clappison: Can I ask you a bit about the type of work you undertake. You mentioned you worked for the Government. What sort of work do you do for the Government?

Bill Waite: There is a mixture. All that I am about to disclose is in the public record, so I am not disclosing any client confidentiality. We worked for the Bloody Sunday inquiry in the context of identifying witnesses and trying to help bring those witnesses to the inquiry to give evidence. We worked for the Directorate of Counter-fraud Services of the National Health Service-we had a permanent secondee there who helped to interview and recruit the senior staff for that, and develop internal processes and procedures; we also helped on a number of investigations around health tourism. We have done other investigations for bits of the Home Office, particularly where there have been allegations of breach of duty by senior officers within specialist units.

Q166 Mr Clappison: Do you work for local government as well?

Bill Waite: No, we haven’t worked for local government.

Tommy Helsby: We have.

Q167 Mr Clappison: You have worked for local government?

Tommy Helsby: Yes, although probably much larger-our government-related work is generally international. We have worked for the public prosecutor for a Gulf State and for the Government of Ukraine. We are currently engaged by the Government of Afghanistan doing a bank fraud investigation.

Mr Clappison: I was thinking more of local government in this country.

Tommy Helsby: I understand. We have done some work for local government here.

Q168 Mr Clappison: What sort of work would that be for local government?

Tommy Helsby: Fraud.

Q169 Mr Clappison: You mentioned physical monitoring of people. What would that involve?

Bill Waite: The case example that I can give was a breach of duty by an internal employee who had been engaged in a £250 million fraud. The individual had been arrested but was released on bail at that point in time. There was a requirement to identify who else was involved in the criminal enterprise and to try to identify which assets he had. So we placed him under physical surveillance and we monitored the individual. We then handed over the surveillance to some police officers, who arrested him, and when they arrested him he was in possession of a large amount of cash. The point behind that is we were working with the police. That case was taken on by another prosecutorial body because the police simply did not have the resource to conduct that sort of exercise.

Q170 Mr Clappison: Is there any sort of work that you would not undertake?

Bill Waite: A lot.

Q171 Mr Clappison: Just given us an idea, in general terms.

Bill Waite: The issues for us are, are we professionally competent to do it? Do we have the physical resource to do it? Is it appropriate to conduct the kinds of investigations that are being asked of us?

Q172 Mr Clappison: Are there cases where you say, "No, we don’t spy on that type of person"?

Bill Waite: Yes.

John Conyngham: Most certainly, if we have concerns. For example, within our firm we have an ethics committee, which last year met 32 times to consider opportunities that were being put our way over which there were question marks as to whether we wished to undertake them. You might be surprised at the number of cases that we have turned down.

Q173 Mr Clappison: Can you give us an idea of the sort of cases you turn down?

John Conyngham: We will very quickly turn down requests to behave in an illegal manner. Again, you might be surprised at the times we are asked by, occasionally, professional advisors whether we can find out things that-

Q174 Mr Clappison: That is not a question of morality. That is a question of law. You know it is illegal.

John Conyngham: That is a question of law, yes.

Q175 Mr Clappison: Do you have morals on top of that, where you say, "No, we just don’t spy on that type of person"?

John Conyngham: No. Many times it will perhaps have to do with the politics of the situation in the particular country. It is not particularly investigative, but five years ago we were given an opportunity for training in Libya. We were told by authorities here that it would be fine for us to do it. Our ethics committee decided it was not such a good idea.

Q176 Mr Clappison: Would you accept employment from, say, a multinational company in this country who wanted to do research into people who were challenging their reputation? Would you accept that sort of work?

John Conyngham: We might do.

Q177 Mr Clappison: You might do? So if the person concerned was a journalist who was writing articles, would you accept that work to look at the work the journalist was doing?

John Conyngham: No.

Mr Clappison: You wouldn’t?

John Conyngham: No.

Q178 Mr Clappison: If it was a member of the public who was, say, challenging the reputation of a company?

John Conyngham: It would depend on whether we could understand on day one whether there was a valid reason for the company to request that type of investigation. Were there circumstances present at that moment in time that made the suggestions that were being made by an individual appear odd, so there was a need to better understand that person’s background?

Q179 Mr Clappison: So you have never carried out an investigation into a journalist?

John Conyngham: No, not to my knowledge.

Q180 Mr Clappison: Is that true of all of you?

Bill Waite: It is certainly true of us, yes.

Tommy Helsby: One of the things that we have, as our equivalent to John’s ethics committee, is our risk committee. There are a number of triggers that would automatically cause a referral of a new opportunity to that committee for scrutiny: the size of it, the investigative techniques that might be involved, the involvement of a government and any relationship to a journalist or journalism. We have undertaken libel cases on a number of occasions, both for newspapers or publishers and for the libelled person. In a sense, that would be a context in which we might well be investigating the journalist’s activity but essentially to understand the nature of the fact base that was produced and so on.

Chair: Thank you, Mr Helsby. Are you done, Mr Clappison?

Mr Clappison: Yes, thank you.

Q181 Lorraine Fullbrook: Can I ask all three of you, have you ever bought or paid for information from an intermediary that is not employed by your companies?

John Conyngham: No.

Bill Waite: We often conduct research in multinational jurisdictions. So if we are doing due diligence for an oil and gas company and we require corporate records on a business in Angola, we will instruct a local law firm to retrieve those corporate records and we might instruct a local newspaper or accumulator of data to obtain that information; so in that context, yes.

John Conyngham: I took your question to mean information brokers.

Lorraine Fullbrook: Yes, exactly, because we have had other witnesses who do.

John Conyngham: That is why I gave a very quick "no".

Q182 Lorraine Fullbrook: The other witnesses we had a few weeks ago do use information brokers and there is no, if you like, due diligence process on how they acquire that information. They just buy it.

Bill Waite: We use third parties in different countries, as I have mentioned. We have worked in more than 100 different jurisdictions since I started the firm 15 years ago. We have an internal process of due diligence around third parties that we use. We have contractual provisions with those third parties that ensure that they at least contract to comply with local laws in relation to what we do and, again, this feeds back into our client base. If you are working for government departments or multilateral organisations, you have to be sure that they can rely on what you are producing, because in the vast majority of cases we are providing information to clients to help them discharge their regulatory burdens, whether it be under the Bribery Act, the Financial Services Act or the Foreign Corrupt Practices Act.

Q183 Mr Winnick: When it comes to working in various countries, is there some sort of line where you say-Libya was just mentioned in passing-"This regime is so obnoxious. Undoubtedly it has carried out crimes against humanity. We can’t accept the contract on that basis alone"? Would that be the attitude?

Bill Waite: Yes.

Q184 Mr Winnick: Definitely?

Tommy Helsby: There are judgments on these issues as to what it is they are asking you to do. If a government that had a poor record on government corruption asked us to assist with developing an anti-corruption programme we would be inclined to say yes, but then we would want to make sure that there was some reality to it and it wasn’t just a public relations exercise where our name was being used to disguise their continued disregard of international principles. There is a concern for our own reputation in relation to these things.

Q185 Mr Winnick: I understand that. In the past, say, in the apartheid period in South Africa-were your companies in existence at the time?-would you have accepted or did you accept work for the Government of South Africa?

Tommy Helsby: I certainly was around then and I can recall turning it down.

Q186 Chair: Thank you. Mr Waite and Mr Conyngham?

Bill Waite: Ours wasn’t in existence but, to use Mr Helsby’s analogy, we were instructed by the Kenyan Government to review its anti-corruption policies and procedures. We did that on the condition that our report would be made public and it was published.

Q187 Chair: Thank you. Mr Conyngham?

John Conyngham: The same. I don’t think we go as far as a kind of ethical foreign policy. We will look at the situation in relation to each particular case and we don’t shy away. Our mission is to help companies succeed in complex and hostile business environments. For example, in other parts of the company, in security-related matters, we may need to assist clients at the present time in parts of Sudan; but there are parts of Sudan that we most seriously will not go near-the Darfur region-and likewise in other jurisdictions. So we will look at the facts.

Q188 Steve McCabe: Gentlemen, you all represent big companies with government contracts, international operations. Do you ever subcontract the work to smaller companies or agencies?

Tommy Helsby: Yes. As Bill said earlier, I think, we have a very rigorous process of screening the contractors.

Q189 Steve McCabe: So you do subcontract. Is that same for the other two?

Bill Waite: No. We do not subcontract work. We use third parties to provide data in certain circumstances.

Q190 Steve McCabe: Let’s not get hung up on the technicality. I am asking: are you entirely responsible for the contract at all times or is someone else, who is not an employee of your company, working for your company to do the work? That is the point I am making. I don’t want to get tied up in a technicality.

John Conyngham: No, we would be entirely responsible for the work at all times. We may request assistance.

Q191 Steve McCabe: But someone else may be doing it who is not one of your employees? This is a simple question. I am trying to establish whether the person who is doing the work at all times works for your company, or they work for another company. That is a very simple question. That is all I am asking.

Bill Waite: Well, it is a simple answer and the answer is that sometimes we use third parties to recover data in different jurisdictions that we feed into our investigation.

Q192 Steve McCabe: So it could be an individual, someone working for another company and not someone working directly for you?

Bill Waite: Generally it is accountants firms, law firms, people of that nature.

John Conyngham: We will have a written agreement incorporating our policies and procedures, in particular things like anti-bribery procedures, confidentiality, data protection. These are all documented in people that wish to work for us.

Q193 Steve McCabe: Obviously you ask them to sign an agreement. I appreciate that. Can you say with absolute certainty that you know at all times that these people who I am referring to as subcontractors-I take the distinction you are drawing-are maintaining the same standards and you can be confident they are co-operating at all times with the principles you set out for your own employees?

John Conyngham: When we do this we are putting our own reputations on the line, so we are rigorous in looking at who they are and ensuring that we monitor them-

Q194 Steve McCabe: I am not saying you don’t try. Can you say with confidence-

Chair: It is very difficult for the Hansard writers when two people speak at the same time. Mr Conyngham?

Steve McCabe: I am just trying to get the answer clear, Chairman.

John Conyngham: I am saying that we choose them with care; we put the paperwork in with care; we monitor them; we visit them. We do not use that many of them because we are now operating in 34 countries ourselves, through our own offices, so that cuts down the need for-

Q195 Steve McCabe: How many would you use in an average year?

John Conyngham: I have no idea, sir.

Q196 Steve McCabe: Well, you operate in 34 countries and you do not use "that many". Is that one per country, or is it maybe more than that?

John Conyngham: Our philosophy will be to do the vast majority of the work in-house. We do not have an office in Turkmenistan. If we need to do some work to gather some public records in Turkmenistan, we will be using local assistance.

Q197 Chair: Mr McCabe’s point is that you have to use people outside your firm. There have to be third parties involved. They will do a piece of work for you. You do not have any control over the way in which they do their work. If you require some information urgently, they will go out and try to get that information. You do not go and check on the methods of every single third party that you contract out to, do you?

John Conyngham: We will have done, particularly over the last few years, increasing amounts of due diligence before anybody in our firm is allowed to use that individual as a subcontractor. We will have, to the best of our ability, checked out their methodologies.

Q198 Chair: Since this has been raised by Mr McCabe, could you write to us? You said you do not know the answer as to how many third parties that you use. If all of you could write to us and just give us a figure-we do not want to know who they are, but a figure-it would be very helpful.

Q199 Steve McCabe: It would be interesting to have some idea who they are as well. I think it would be quite interesting to see what kind of other companies get involved. I am not trying to accuse you gentlemen of anything. I am simply trying to understand what kind of network we are dealing with and what kind of subcontractors are, involved because I am curious to know how you are able to maintain your controls over these people.

Chair: Mr Waite, you were eager to say something.

Bill Waite: I was eager to say that the data that we are requiring third parties to supply to us is generally public record data; therefore, the prospects of trespassing on local laws, whether they be data protection laws or any other laws, are very, very remote. We are asking law firms or accountancy firms or media collators to produce records to us. That does not risk one trespassing on local laws.

Q200 Steve McCabe: When you say "generally", does that mean always, or that there may be occasions when it is not?

Bill Waite: I would say in about 95% of cases it is that kind of inquiry and, again, most of the work we do in terms of complex investigations will be done with law firms. If there is other investigation that is required, in those circumstances we will be talking to the local law firm to ensure what the local regulatory environment is, for the very reason that we do not want to fall over and either end up with inadmissible evidence or difficult evidence.

Q201 Chair: None of your firms have ever paid a police officer or a public official for information? Is that right?

Bill Waite: No. We are currently using a police officer as a subcontractor to review a Metropolitan Police investigation into a murder, to produce an expert report on whether that investigation was conducted competently.

Q202 Chair: A current serving police officer?

Bill Waite: No.

Q203 Chair: An ex-police officer?

Bill Waite: A retired police officer.

Q204 Nicola Blackwood: I just want to clarify one point. Have you ever employed or used a third-party subcontractor in the UK?

Bill Waite: Yes.

Q205 Nicola Blackwood: Could those also be included in the report that you send to us following this?

Chair: In the note.

Nicola Blackwood: In the note that you send.

Q206 Chair: Could you write to me with that information? My clerks will write to you with a list of things that we want from you.

Q207 Nicola Blackwood: The second point I wanted to clarify is: on what grounds would you refuse to use a subcontractor or third party?

Tommy Helsby: We have a process through which we allow contractors to be on our list. We require a background check; we want to inspect whether or not they are licensed, if they are in a jurisdiction where a licence is required, and that that licence is current. We want to know who their shareholders are, if it is a corporate entity that we are dealing with. We do our own background check on who they are.

Q208 Nicola Blackwood: How do you establish that in the UK, given that we do not really have a regulatory environment?

Tommy Helsby: I am saying where there is one, because we have work going on all over the world.

Q209 Michael Ellis: Gentlemen, your companies are international. They are corporate and at the quality tier, you would argue no doubt, of the industry that you represent. But what about those who would not be quite so ready to come to this Committee and speak on behalf of their conduct? What about those in your industry whose standards fall far short? We know that they exist. I ask you to confirm that you also acknowledge that they exist and that they are prepared to cut corners and to operate under improper standards. How do you feel they should be best regulated? Is it your view, for example, that there should be statutory regulation of your industry, further statutory regulation?

John Conyngham: Yes. Not further-this could have been implemented; obviously the regulations could have come out under the present legislation and it has not happened-but certainly for certain activities that are intrusive, where the public have every right to feel that there should be protections in place. They are set out in the core competency areas in the 2007 PRIA. If it involves surveillance or formal interviewing in a criminal context, there should be licensing to cover those matters. The area we are suggesting at this time that should not be covered, and potentially is covered by the way this Act is worded at the moment, is commercial, regulatory and legislative due diligence that companies are required to do. At the moment it is covered in this legislation. It is not done by ex-police officers.

Q210 Michael Ellis: You accept, Mr Conyngham, that there are those that operate in your industry far below acceptable standards? Do you accept that?

John Conyngham: I think there is a very small minority, and I do not think one should underestimate the effect that data protection legislation has had on this industry. It has done a good job in weeding out. Companies themselves or people wishing to employ investigators now have a pretty good idea of the parameters of what is allowable and what is not allowable. Data protection has been around since 1998-a long time.

Q211 Michael Ellis: But Mr Conyngham, improprieties still take place, don’t they?

John Conyngham: I am sure they do.

Q212 Michael Ellis: Mr Helsby?

Tommy Helsby: If I could just say regulation of the industry will not necessarily change what is going on. What we are talking about is people who are breaking existing laws. Those laws exist, they are around, and people are breaking those laws. To institute some level of regulation is not going to change that. There will still be people out there who are willing to break the law. But I do think that having regulation creates an opportunity for, as it were, the innocent client to be protected. At least the client who goes to a licensed investigator has some confidence in knowing that the things that the investigator will do will be within the law, because with many of the laws that we are talking about there is strict liability. If the investigator breaks the law, the client is held liable as well.

Q213 Michael Ellis: You would argue that further regulation simply adds to the burden of the law-abiding and does not have an effect on those who are prepared to circumvent the law in the first instance?

Bill Waite: That has never been our argument. As I said at the beginning, we engaged with the SIA in 2003, 2006 and 2007 on the basis that regulation of certain activities should be statutory and those activities-

Q214 Michael Ellis: You contributed to the process in 2007, did you?

Bill Waite: We did. Two of us, Control Risks and Risk Advisory, were on the stakeholder advisory board to the SIA from about 2004 to 2006, 2007. We contributed to the competence discussion in 2007. We engaged with the SIA again in 2008, and we have written correspondence in relation to that. All of our discussions with the SIA have been about, "If you are going to have regulation it should be risk-based regulation. It should be focused on what the original Act was focused on, which was where is the risk of harm to the public?" The competencies or the areas that the public were at risk from were things like physical surveillance, search and seizure of evidence, formal interviewing processes. That is what is in the competence requirement and that is what should be formally regulated, and it should be statutorily regulated.

Q215 Lorraine Fullbrook: I would like to follow up on that if I can. The Government announced in October 2010 that there would be a planned transition to a new regulatory regime for the private security industry. One of the witnesses we had before us-granted, they were associations of smaller private investigators-has suggested that a system of co-regulation, involving effectively self-regulation by the industry, should be backed by a statutory regulator. Do you think this would work-self-regulation?

John Conyngham: Very briefly, we do not think co-regulation would work because we do not think there is any industry body that represents the entirety of the industry that you are beginning to see now. So we think it should be statutory regulation.

Bill Waite: You are dealing with very sensitive issues. In other areas of professional conduct the entire move has been away from self-regulation, and I am thinking about the Bar Standards Board for example. So to engage in partial regulation or self-regulation in an area that is as sensitive as this I don’t think would work. It would not be credible. It would not be effective. There is not a body out there that could engage with this. There isn’t the funding for it. So I think all of those arguments are very weak.

Q216 Lorraine Fullbrook: Mr Helsby?

Tommy Helsby: Just following on from that, one of the things that I think we are very keen to encourage the SIA or its successor to undertake is a recognition of corporate licensing as well as individual licensing. My company has 400 employees. Perhaps a dozen of them are engaged in activities that might be subject to this regulation. To require all 400 of them to be individually licensed, to pass exams, would be a severe burden.

Q217 Lorraine Fullbrook: The Government’s proposals are to have the businesses licensed and in certain circumstances individuals would be licensed, which I think answers my question. You do not agree with self-regulation, therefore you would not have an organisational body to oversee that. You would prefer just straight legislation?

Tommy Helsby: Yes.

Q218 Alun Michael: You have suggested that legislation would weed out the lawbreakers. I do not quite understand that. Surely it is regulation that closes down those who do not stick to the rules?

Bill Waite: I am not sure I did suggest that. I think I suggested that statutory regulation should be there for specific activities because it sets standards.

Q219 Alun Michael: Okay. Within a system of licensing, should it be focused on individuals or companies or both?

Bill Waite: It has to be both, because there are a number of one-man bands. There is a small industry out there that services private clients. Our recommendation to the SIA, and our communication with the SIA throughout the period I have indicated, is that there should be corporate regulation. If you look at the FSA model in terms of financial services, it is up to the organisation to demonstrate to the regulator that its people are fit and proper, that they have adequate qualifications and that they have been through the appropriate training. I think that that is the obligation that should be shifted to the corporate. There would not be sufficient resource within a regulator, I would suggest, to investigate those issues down to the minutiae.

Q220 Alun Michael: There are management responsibilities, but you would accept that both the individual and the organisation would have responsibilities?

Bill Waite: Indeed. I think the corporate should have responsibilities around the fitness and properness of its people and the training they go through-ensuring that they do not have any criminal convictions and that they do have the adequate skills and experience-and to ensure that within itself it has appropriate procedures and controls for issues such as data protection and regulatory methodology. I would also suggest-this is outside the remit of what the SIA has been discussing-there should be a requirement for companies to carry professional indemnity insurance. At the moment we are very much engaged in, "If you breach the law you lose the licence," but recourse for the individual that is affected has to be there as well. Waiting for a criminal prosecution or a fine that goes to the central treasury is not the same as having recourse to a fund in the form of insurance, which would give them-

Q221 Alun Michael: Would I be right in thinking that you would also want the situation to be one where the loss of a licence means loss of ability to trade?

Bill Waite: Indeed.

Q222 Alun Michael: It has been suggested that licensing could be split into a number of different subcategories-things like surveillance, data research and so on. Do you think that that would be workable?

Bill Waite: I think we all have a concern, which is the breadth of definition of designated activities under schedule 2 part 4, because if you read what that says, it covers, for instance, the activities of a headhunting firm. There is a significant percentage of our work that is directed to ensuring our clients comply with regulatory burdens that are imposed on them that have nothing to do with investigations in the context of surveillance, formal interviewing, or search and seizure.

Q223 Alun Michael: No, but if you have a situation where organisations are undertaking a wide variety of different functions, as all three of you have said your companies do, there is a need to be precise, isn’t there, about the different aspects of activity?

Bill Waite: That is precisely right, and what we are saying is that there are certain activities that should be licensed-we have touched on them and the SIA came up with them in 2007-but there is a swathe of activity that is or might be caught by the current definition of this Act that should not be.

Q224 Alun Michael: Why not?

Bill Waite: Because there is no demonstrable risk to the public. In fact the contrary argument is maintained-that what we are essentially doing is helping our clients comply with their statutory obligations. I am talking about regulatory due diligence.

Q225 Alun Michael: I think it would be useful if you could expand on this in a note perhaps. I can see where you are leading us but it probably leads us into too much detail for this session.

Q226 Chair: I am sorry to stop fascinating questions and answers but we do have other witnesses. What I am proposing to do is we will write to you with specific questions and ask for specific information that you can give us. But in summary, your plea to this Committee is, "Please regulate the industry." Is that what you are all saying?

Bill Waite: We have been asking for that since 2003. So I think it is time to move it on.

Tommy Helsby: We are glad you are paying attention.

Chair: Thank you very much for coming in. We will be writing to you for further information. We might see you again.

Examination of Witness

Witness: Charlotte Harris, lawyer, gave evidence.

Chair: Ms Harris, thank you for coming to give evidence to the Committee. I apologise for keeping you waiting so long.

Charlotte Harris: That is fine.

Q227 Chair: We are most grateful. We know that you have already given evidence to Lord Justice Leveson.

Charlotte Harris: Yes.

Chair: Therefore, we may refer to the evidence that you gave to him in our questions to you today.

Could you tell us about your own experience? There you were, a partner in a very famous firm of solicitors, dealing with a number of very famous clients, including Members of Parliament, none who are present here today, I think, and you found yourself the subject of a private investigation. Is that right?

Charlotte Harris: No.

Q228 Chair: It is not right?

Charlotte Harris: No, it is not. I was a partner at a very good law firm, but possibly less famous than Mishcon de Reya. I was in Manchester, and I think that is significant actually. At the time I had just become a partner, and I think I was not an individual who was known at all in the press, or particularly at that point within the industry. I was a young mum and lawyer doing her best, having come across this particular set of cases and having come across the phone-hacking scandal at a provincial law firm in Manchester called JMW.

Q229 Chair: You are now with Mishcon de Reya?

Charlotte Harris: I am now a partner at Mishcon de Reya. There are two surveillance reports, so I will talk about them separately. By the time we get to the second surveillance report-there is no evidence that it came from News International and we do not know whether or not that was Derek Webb, but I don’t think it was-at that point I was at Mishcon de Reya as a partner. Certainly, at that time, I had looked after more cases that had been reported on.

Q230 Chair: Are you saying that in 2010 you were the subject of an investigation?

Charlotte Harris: Yes. I am trying to get the dates right. The first report, which is the Derek Webb report, is 2010, I think. I was still in Manchester at that point and it is very early on.

The chronology of it is that I had done a case-my first case as a partner-for Max Clifford, which was quite a big one to start with; it was Max Clifford’s phone-hacking case. We had been successful in that in that we had got an order from Justice Vos for disclosure. It was disclosure of the documents that now more people know about and have now been the subject of numerous proceedings and the police have notified victims, but at that stage phone-hacking wasn’t known. Max Clifford had resolved the case, and certainly he has been very helpful moving forward in letting other people know what the position is. At that point I also initiated a claim for Skylet Andrew. To put it into context, five people were named in court when the Princes had taken their claim and Clive Goodman had gone to prison, along with Glenn Mulcaire. At this point News International was still saying that there was a one-rogue defence and that it had nothing to do with them, but there were five others.

Q231 Chair: Yes. Obviously this is a very large area. The Committee is very keen to hear your evidence about the private investigation surveillance of you. That is what we would like to concentrate on today.

Charlotte Harris: Sure, but it is very important that you understand the context of the Derek Webb surveillance. It would mischaracterise it if I came here and said, "Yes, I was a partner at Mishcon de Reya and they followed me around," because that is not what happened. The underlying reasons for putting somebody under surveillance should form, I would hope, some of the considerations in terms of regulation going forward.

The reason behind it and the reason behind Derek Webb’s surveillance of me, a person who wasn’t in the public domain and who was from a law firm in Manchester, was that I had stumbled across, with others, a ream of criminal activity that News International didn’t want to come out. They believed that I was sharing this information, which I wasn’t, and so the email documentation that has been referred to said, "Shall we send somebody up to Manchester? Let’s try to stop this." It was around the time of the election as well-it wasn’t going to look good. There was no reason at all to write any kind of article about any kind of scandal that would involve me because nobody would care. It would be of no interest at all.

Q232 Chair: So it is the context of specifically the information that you had discovered?

Charlotte Harris: So that they could put me and the other lawyer, Mark Lewis, under pressure and-it was clear from the documents-to stop working on these cases. The view that I gave to the Leveson inquiry is the same view as I will give to you, which is in those circumstances the appropriate thing to do is to write a letter to one’s senior partner and make a complaint if you think that there is intimidation.

Chair: Yes, we will come on to that.

Q233 Mr Winnick: How were you aware in the beginning, Ms Harris, that you were subject to investigation-what you have just been describing?

Charlotte Harris: The first time I became aware that I had been under surveillance was when an associate of mine, a client, told me that he wanted to meet-this is a year later-and gave me a surveillance report that had been circulated. It was not the surveillance report that had been taken while I was a partner at JMW. It was one when I had clearly just started at Mishcon de Reya, and it had lots of information about my move down to London and my children and my personal life and so on-incorrect information and correct information. When I got it I thought that News International may have been behind it, simply because they-

Q234 Mr Winnick: Can I just interrupt you there? You immediately came to the view that News International was likely to be behind it?

Charlotte Harris: No, I didn’t say that. I didn’t come to the view that they were likely to be behind it. I came to the view that they may have been behind it because they were mentioned within the documents. I certainly didn’t jump to any conclusion, which was why I spoke to Simon Greenberg at News International within days and brought him the report and showed it to him and said, "Could you look into this for me?" He assured me that they were not responsible for that report, but what he did do and what led to the Derek Webb surveillance-

Q235 Chair: Sorry, could you just tell us who Simon Greenberg is?

Charlotte Harris: Simon Greenberg was part of the management committee board who had been brought in to resolve the phone-hacking claims and remains there. It is called the MSC.

Q236 Chair: The board of News International?

Charlotte Harris: That is right. I brought it straight to them. I thought that was appropriate, to say, "Look, I’ve got this. It has been given to me and your name is in it." It said within the report that surveillance had been undertaken on me and other lawyers in order to put pressure on us and stop us from doing these cases, so I thought it was appropriate to ask him if there was anything he knew about it. He said that he would look into it and he did. What he did was have a look in Tom Crone’s office and there we find the Derek Webb surveillance of the year before, which News International then said they had commissioned. It was commissioned with Farrer, who were their lawyers at the time. It was not jumping to a conclusion. Going to see Simon Greenberg at News International led to the discovery of these documents that were then handed to the police. The police let me see the file, which was really quite vast. When I say vast, it was vast compared to other evidence I have seen on other people. I looked through it and then I gave what evidence I could.

Q237 Mr Winnick: There is no doubt at all it was authorised by News International?

Charlotte Harris: No, they admitted it-the Derek Webb surveillance of when I was a partner at JMW. so when I am at the end of Max Clifford’s case and the beginning of Sky Andrew’s case, when we are getting there in terms of disclosure and uncovering the evidence, it is at that point that there is surveillance on me and others.

Q238 Mr Winnick: The only reason that was done was because the firm was representing-you were obviously involved-victims of phone-hacking?

Charlotte Harris: Yes. I was the only person at the firm working on it.

Q239 Mr Winnick: As regards your private life-you did mention it-did they go into details of whether it was accurate or not about you?

Charlotte Harris: They had a look and they said that it was inaccurate. They couldn’t find anything.

Mr Winnick: How disappointing for them.

Charlotte Harris: Yes.

Q240 Mr Winnick: What about your children, because you have made a reference that you felt so uncomfortable with their looking into your family and children? Is there any indication that they were in fact doing that?

Charlotte Harris: My children were two and four at the time. They had my children’s birth certificates. I know these things are on public record but, when you are a lawyer and you have written a letter to the other side and they don’t like the content, the correct response is not to say, "Let’s have a look at her children’s records." It is just not the right response.

Chair: I think we would accept that.

Q241 Nicola Blackwood: You have given us a narrative that is quite straightforward. You went to News International and they immediately-

Charlotte Harris: It was as straightforward as that.

Q242 Nicola Blackwood: What was the response of News International? They just held up their hands and said, "Yes, we have been investigating you"? That is not the sort of response we received when trying to get answers.

Charlotte Harris: I understand. I went in. I was very nice.

Nicola Blackwood: We were quite nice.

Charlotte Harris: I know. I went in, but I think they were surprised, or Simon might have been pleased at how direct I was. What I didn’t do was get this material and do what I had been accused of within the material for the surveillance to be put on me in the first place, which was to use the material, to leak it anywhere and so on. I would always take that straightforward approach. I went in, showed him the documents and said, "What is this? Please look into it." He said, "Yes, I will," and it only took a small amount of time for him to say, "Okay, I didn’t think we had anything to do with the second document but we have found this." Given the situation at News International and the MSC, if they are under an obligation to look into-having been caught out on disclosure before-their lawyer’s room and they find something, they have to give it over to the police now, otherwise they would be in even more difficulty.

Q243 Nicola Blackwood: Have you established who was responsible for the second document?

Charlotte Harris: No. No, I don’t know. It was better than the first, I think.

Q244 Nicola Blackwood: What was the response of the police when you handed this over?

Charlotte Harris: Well, the police were given the document by News International. I gave the police the first set of documents that had the second report in, and then Simon Greenberg and the MSC, as I understand it, went through all the emails and so on and gave the police that material. The police then called me in and I looked at it. They showed it to me. The police don’t normally give you a particularly emotional response to that.

Q245 Mr Clappison: Can you tell us where the second document came from?

Charlotte Harris: I am not going to say who the client was, because I don’t think that is fair, but they were given it, so it was clearly in circulation somewhere.

Q246 Mr Clappison: But News International said it didn’t come from them or wasn’t anything to do with them?

Charlotte Harris: News International said it didn’t come from them. I believe them on that document.

Q247 Mr Clappison: You mentioned before about the role of Farrer, the solicitors, in this. They presumably had not known about the first set of-

Charlotte Harris: They commissioned it. It was their idea, not Tom Crone’s. Looking at the emails-this has been covered in Leveson when Julian Pike gave evidence, so this is nothing particularly new. Julian Pike said that he believed that there was some leakage of information-in my opinion rather unconvincingly because, as I said, just tell the Law Society or the Bar Council-and that the best thing to do, and he recommended to do, would be to put me under surveillance.

Q248 Mr Clappison: I find it slightly strange-

Charlotte Harris: So do I.

Mr Clappison: -that the instinct of a firm of solicitors would be to put personal surveillance on somebody involved on the other side.

Charlotte Harris: Well, he should have just asked me.

Q249 Steve McCabe: I don’t know if you heard our earlier witnesses.

Charlotte Harris: No, I haven’t.

Q250 Steve McCabe: They all represent big private investigation companies and they were telling us about the high ethical standards they employ. In the situation that was applied to you, I presume you would not think there was a fairly high ethical standard employed in the surveillance that was undertaken in relation to you?

Charlotte Harris: There is a vast variety of different types of private agents. I don’t think that all PIs are terrible people. I think there are some good helpful people within the industry and they are essential for all sorts of reasons. I don’t know, because in any report that I have seen in relation to me they didn’t write down their methodology, so you don’t know. Certainly there are some bits of information that can be found out about a person, or in my case about me, perfectly legitimately-for instance, birth certificates and so on. My grouse with this is the reason for putting somebody under surveillance inappropriately, finding out something in order to harass a person or to have some kind of political influence-for instance when MPs have been put under surveillance and for what reason. It might in some cases be because they are on a fishing expedition for a story, if a newspaper has commissioned somebody, or it might be to harass them so that they can gain some kind of power or advantage. That is wrong. It is the reason behind the commission I have a grouse with. Obviously there are certain methods-I don’t think it is right to go through people’s rubbish and certainly phone-hacking is just out of the question; I don’t think that blagging is right. There should be some transparency, but they also do often behave very well and perform an essential service.

Q251 Steve McCabe: When they don’t behave well-I mean, when they root through your rubbish-and-

Charlotte Harris: They know when they are breaking the law.

Q252 Steve McCabe: You questioned the basis of it being commissioned and if they get the facts wrong and then they are passed to somebody, should you have some automatic right to complain when that happens?

Charlotte Harris: Well, you can complain, because the laws in place are that if somebody breaks the law, then you can do something about it. You can sue them. There is nothing that is illegal, as it stands, in watching somebody, but there is a boundary that gets crossed, and I am not sure that everybody knows what the boundary is. What I can say from experience is I look into many cases that involve private detectives-cases that involve both surveillance and counter-surveillance, or use of private detectives in terms of fraud or in terms of finding out about somebody’s debts and so on. It tends to be that where you have a "dodgy commission", if I can call it that, a dodgy agent that gets used. There are lots of reputable agencies and there are lots of reputable reasons why you might need to use a private investigator. If you want to look into something that perhaps you ought not to look into then you might use somebody else. I know many who tell me that they burn their notes.

Q253 Steve McCabe: I want to ask this one last question. You said, yes, you can complain. You can sue them. Are you satisfied that that level of legal redress is sufficient for the ordinary person who discovers they have been invaded in this way?

Charlotte Harris: In terms of regulation, I am always worried personally about both self-regulation and external regulation. You want to get it right. The laws are in place already and if they work and people do take action then the laws are there. However, if there was properly managed regulation where people can find a shorter, cheaper route, then that would be a good thing in terms of complaint particularly from people who don’t wish to spend a vast amount of money. I think that it is about letting people know that if they are going to commission a private detective, they use somebody reputable and that the reputable person is not going to break any laws. Law firms have to do that anyway.

Q254 Mr Clappison: You have been careful to emphasise your concern about the reasons why people have surveillance put on them, but can I ask you a little bit about the actual type of surveillance used. From what you saw of these documents, did you form the impression that you may have been followed personally yourself, or members of your family may have been followed, without your knowledge?

Charlotte Harris: Well, it did say so. There were pictures of the house, and it was quite clear what had happened. There were pictures of the house. They had come up to see whether they could-I am not sure-see an exchange of information or whatever they wanted to see. I don’t think that the notes necessarily gave vast detail of the amount of surveillance but-

Q255 Mr Clappison: You had been followed around?

Charlotte Harris: I don’t know how much I was followed around. I think they might have had a post and watched from there.

Q256 Michael Ellis: Ms Harris, how did this associate get a copy of the report itself?

Charlotte Harris: I don’t know.

Q257 Michael Ellis: I ask because not everyone would be in your position of having a third party inform them that you had been under surveillance. I don’t expect you to tell us who the associate was, but how did he or she get hold of the report?

Charlotte Harris: I suppose the best answer I can give is that I deal with individuals who have privacy issues themselves. I am a privacy lawyer, so the kind of cases that I deal with are cases where there is sometimes surveillance or counter-surveillance going on, blackmail threats, all sorts of very unpleasant things, and so sometimes they might know that-

Q258 Michael Ellis: Was it another journalist?

Charlotte Harris: No. It wasn’t. Just to make it clear, it was not a journalist.

Q259 Michael Ellis: From a rival publication?

Charlotte Harris: No. This was a business associate; not a journalist, not an MP and not anyone who anybody has heard of.

Q260 Michael Ellis: Could you tell from the report, which you then read, what the tenor, the reasoning or the rationale for the report being requested in the first place was? Very often the preamble to these reports outlines what the reason for the commissioning of the report was.

Charlotte Harris: Yes. I can go through it. Just to take care, because obviously I am giving evidence to you, let me say that I suppose some of you may have heard of the person. I don’t want to make a sweeping statement saying nobody would ever have heard of them. I suppose it is possible to make that statement with a caveat: "probably not". But I don’t know who everybody knows.

The report that I was given, that one where I don’t know the origin, I think it was clear from that, because it basically said what it was, that the idea of the report was to find out private information about the main lawyers who were involved in the phone-hacking litigation-personal information-between them, so that that could be utilised if need be. I am not saying that this is News International but that report, it could have been-it looked a bit like a sort of gossip draft, as much as anything else.

Q261 Michael Ellis: So it was focusing on private life as opposed, for example, to spending habits or another type of business client?

Charlotte Harris: Private life, political affiliations, career aspirations, that sort of thing; how well people got on.

Q262 Michael Ellis: You think it was designed to embarrass or to intimidate? Do you think it was designed to allow another party to exercise influence over your moves?

Charlotte Harris: It said it was.

Q263 Michael Ellis: I see. Do you think regulation would have prevented that from happening to you?

Charlotte Harris: Nobody regulated could, I think, have got the information that was in that report. I have thought about it quite carefully. I do not want to go into what was in the report, because that defeats the object of keeping it private, but there are certain bits of information that I just simply cannot understand how they could have been got from a public register, or even by following-

Q264 Michael Ellis: I understand. My final question is: if further regulation was put on some elements of the industry, do you think that would have the effect of simply burdening the law-abiding elements and that it would be ignored by those who operate in the darker recesses of the industry, or do you think it might have the effect of stopping impropriety within the industry that currently exists?

Charlotte Harris: It would make things easier for those who were commissioning a private detective for legitimate purposes if there was some form of code of conduct that people followed, however that works. That would make it easier. As for the perennial problems-the questions of whether everyone will go into the shadows, and whether it will be a burden to those who are law-abiding-I am not sure that anyone who is law-abiding particularly minds regulation, except if it is external regulation that becomes so bureaucratic that it becomes difficult to get the job done at all, which without hearing your evidence, I cannot tell.

Chair: Thank you very much. Lorraine Fullbrook has the final question.

Q265 Lorraine Fullbrook: Thank you, Chairman. There are two small final questions. You say Farrer initiated the surveillance on you?

Charlotte Harris: It was their suggestion, yes, and they commissioned-

Q266 Lorraine Fullbrook: Is this normal practice for law firms?

Charlotte Harris: No. If you were looking into a fraud case or a case where you had a blackmail element and were trying to find out about it, and there were legitimate reasons that you would be very open with the judge about, you might hire somebody reputable. But if I did not like what the other side were writing to me and I thought, "I know, I’ll have a look through their parents’ bins and see where their children were born," I don’t think that would go down well.

Q267 Lorraine Fullbrook: Thank you. I would like to ask about the legislation. The way it is currently framed means that even if regulation for private investigation were introduced, investigations for journalistic purposes would be excluded. What would you think of that?

Charlotte Harris: Investigative journalism has to be protected-good, proper investigative journalism at its best. We have the best and the worst of journalism in this country. So, yes, I can understand where the exclusions are, but what the newspapers must not do is get a private investigator, get him an NUJ card and say, "All right, you’re now excluded." That needs to be looked into, because what Tom Crone said to the Leveson inquiry-I think it was to Leveson, wasn’t it, because he gave evidence to the various committees-was that Derek Webb was a journalist, so it was okay. If you are going to go forward with this and say that it excludes journalists, then you are going to, I would have hoped, need to look into the NUJ and make sure that people really are journalists and not private detectives who are just obtaining a card by filling in a form, because that would be a loophole that they will all jump through.

Q268 Chair: That is very helpful. We certainly will look at that and bear that in mind. You certainly seem to have taken this all rather well. It is a rather extraordinary set of circumstances.

Charlotte Harris: I am a mum. I have to take things well. I have a job to do; I am a lawyer.

Q269 Chair: Were you shocked or surprised? If you were describing your reaction when you first saw that surveillance report, what was it? How would you describe it?

Charlotte Harris: I took my own advice. The first thing I do, or the first thing I advise if somebody shows you a threatening document, is if at all possible tell your nearest and dearest and loved ones and people who are close to you. That gets rid of 90% of the stress of a threat. It is not always possible. I just took it home, showed it to everyone, said, "Look." So then you feel a bit more relaxed. Then I went direct to who I thought the source was. I am in a very privileged position in that I am used to looking at this kind of thing. It just happened to be on me, and I went into autopilot of, "This is how you respond." I might get very cross later, but when you are busy and you have similar cases for clients, and you are also working and looking after your family, there wasn’t a huge amount of time for a vastly dramatic response.

Chair: Indeed. We are most grateful to you. We know you must be very busy. Thank you very much for coming in today. We may write to you about one or two other issues.

Charlotte Harris: Absolutely. Thank you.