CONSULTING
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DIGITAL FORENSICS
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E-DISCLOSURE
LEGAL NEWS Issue 2
www.cclgroupltd.com
HENRY V NGN OR HENRY V JACKSON?
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What does the long-awaited decision in Henry v vely supports business objectives. NGN Ltd mean for the regime of costs budgeting?
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ment methodology to reduce the risk of IT projects Sylvia Henry, a social worker for Haringey ure they Council, are completed oninvolved time, to in budget andP who was the Baby
ectives.case, was the subject of a series of libellous articles in The Sun following the baby’s death in 2007, described as a ‘sustained and vitriolic campaign’ calling for her dismissal.
Ms Henry’s lawyers, the prominent media firm Taylor Hampton, started proceedings against News Group Newspapers (NGN), who own The Sun, in March 2010. NGN ultimately settled in June 2011. This case was one of the first to be subject to the costs budgeting pilot under Practice Direction 51D, the Defamation Proceedings Costs Management Scheme – widely seen as a key test of the upcoming Jackson Reforms. PD51D, para 5.6 states that, ‘When assessing costs on the standard basis, the court: (1) Will have regard to the receiving party’s last approved budget; and (2) Will not depart from such approved budget unless satisfied that there is good reason to do so.’ Despite coming to a settlement, the parties were unable to agree on the amount of costs recoverable by Ms Henry. Costs had exceeded the approved budget by around £300,000, representing an eightfold increase compared to what had been approved. And although the respondent requested a costs management conference shortly before the trial, neither party had
sought the court’s approval for any revised budget. During detailed assessment proceedings, Senior Costs Judge Hurst, acting in line with PD51D, was not satisfied that there was good reason to depart from the approved budget, and therefore disallowed £268,832 of costs. This decision was however, subsequently overturned by the Court of Appeal in January. So where does this leave us in relation to the Jackson Reforms? This case has the potential to significantly undermine the costs budgeting reforms coming into force in April; and raises the question: what latitude to depart from approved budgets does this decision actually afford us post-April? A number of commentators have suggested that this decision seriously undermines the Jackson Reforms and the decisions of costs judges, paving the way for satellite litigation post-April. The sole purpose of the new rules is to constrain costs and ensure that they are proportionate to the value of the case. If the decisions of costs judges can be so easily over-ruled, then this casts doubt on whether the Jackson Reforms will be able to achieve this aim, and raises concerns as to whether they may, in fact, create more uncertainty rather than remove it. However, the words of Lord Justice MooreBick in the judgement seem to clearly
N THIS EDITIO N... > Hen ry v NG N > Tho ught month s of the > The Jackso n Refo > Pot rms ential s ources of ESI > BYO D > DB As > Wh y CCL? > CPD course
indicate that the Henry case will not have such a damaging effect on the Jackson Reforms. Moore-Bick LJ observed that the ‘rather unusual circumstances of this case’ mean that ‘those rules, which will become effective from 1st April 2013, differ in some important respects from the practice direction with which this appeal is concerned’ – indicating that, in this case, the decision to allow departure from the original budget was very much fact-led and case specific, and will not create a precedent which threatens to undermine the Jackson Reforms. Whatever the outcome – the lesson from Henry seems to be that it will be a brave lawyer who seeks the latitude to depart from approved budgets under the new rules. Lawyers must endeavour to adhere to approved budgets, and ensure that they go back to the court for any revisions to the budget. Early co-operation, consideration and discussion on e-disclosure is something that is encouraged by the new rules. For CCL’s view on the lessons we can learn from Henry, and their relevance to the forthcoming Jackson Reforms, please visit CCL’s e-disclosure blog on our website, where you can read the full article: www.cclgroupltd.com/EDblog
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UMAR YASIN, Counsel Umar is responsible for helping law firms involved in litigation to understand, identify and fulfil their electronic disclosure obligations under Practice Direction 31B and the forthcoming Rule 31.5A of the Civil Procedure Rules. Umar also helps clients to use CCL’s services and solutions for risk and compliance purposes. A barrister by background, Umar was Called to the Bar by Lincoln’s Inn in 2008, and then spent nearly four years working in the most rapidly-growing business unit within Thomson Reuters, Findlaw. At CCL, Umar has worked on a number of challenging commercial cases, where he has been able to understand and appreciate the importance of a forensic approach to e-disclosure. Umar has also enjoyed working closely with CCL’s corporate clients on matters ranging from OFT investigations to employee fraud allegations.
Umar’s thoughts for the month Despite writing this from Stratford-upon-Avon, I am really resisting the temptation to quote from Shakespeare. Instead, let us keep in mind that famous line in Bleak House by Dickens, who wrote that ‘the one great principle of English law is to make business for itself.’ It is against the backdrop of this commercial reality that the Jackson Reforms are attempting to avoid creating the situation for our clients so pithily described by Voltaire; ‘I have been ruined but twice in my life, once when I lost a court case, once when I won.’ The Jackson Reforms are meant to control costs in civil litigation and attempt to provide some balance between the ultimate aim of the parties, and the costs incurred in achieving that aim. The addition of the words ‘and at proportionate cost’ in the overriding objective to the CPR is the clearest signal that these reforms are intended to usher in a new era in civil litigation, where costs are closely controlled as part of the overriding objective and the existing powers of the court to actively manage cases is bolstered. The inclusion in the overriding objective of paragraph (f), ‘enforcing compliance with rules, practice directions and orders’ also shows that we can expect rigid enforcement of both existing practice directions and those yet to be published. I have written a more detailed overview of the Jackson Reforms, and how they apply to disclosure specifically, in this issue of Legal News. The full article, discussing some of the wider implications, is also available on CCL’s e-disclosure blog: www.cclgroupltd.com/EDblog
ROB SAVAGE, e-Disclosure Solutions Manager Rob is a digital forensics specialist with a background in e-disclosure, data analytics and counter-fraud strategy. He has worked on, and project managed, a broad range of digital forensics and e-disclosure projects, ranging from multi-national FCPA investigations to small scale IP disputes. Rob has experience of working within a number of sectors including retail and investment banking, pharmaceutical, manufacturing, insurance and defence. Rob’s role as e-Disclosure Solutions Manager at CCL means he is involved in all aspects of delivery, from pre-delivery consultancy and project management to technology selection and implementation.
Rob’s thoughts for the month I have spent a significant amount of time this month speaking to litigators about the future of e-disclosure. I think we are all aware of the changes coming in April, and the impact these will have on costs and proportionality; but bubbling beneath the surface is a technological revolution that has the potential to disrupt and derail future e-disclosure exercises, if it is not at least considered and mitigated. In this issue I have written a piece on Bring Your Own Device (BYOD). What concerns me most about this is not the inherent privacy issues, as these can at least be planned for, but the uncontrolled nature of the data contained upon these employee-owned, mobile devices. The question as I see it is: will we be able to continue to de-scope mobile devices on the assumption that all data stored on them is also stored centrally, and at what point does analysis of these become proportionate?
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THE JACKSON REFORMS ON DISCLOSURE By Umar Yasin Lord Justice Jackson’s 554-page report on costs in civil litigation was published back in December 2009, and, at the time of writing this article, the Ministry of Justice has just recently published the amendments to the Civil Procedure Rules arising from Jackson’s recommendations. By the time you read this, there will be less than a dozen working days before the reforms come into force. So I will go straight on to what the new Rules say about disclosure. At its crux, the new Rule attempts to encourage co-operation and discussion between the parties on the disclosure of documents, whether paper or electronic. Parties are now under an obligation to file a report at least 14 days before the first case management conference, which details what documents exist and where, the cost of giving standard disclosure and which one of the new disclosure orders from the six options that the parties seek. The parties must then meet, or discuss by telephone, at least seven days before the first case management conference, in order to try and agree a proposal for disclosure. Rule 31.5A makes it clear that where electronic documents are to be disclosed, Practice Direction 31B will also apply, and where this is the case, then the report for the first case management conference may also include the completed ESI questionnaire appended to Practice Direction 31B. Jackson identified that ‘even in medium-sized actions, disclosure of documents is usually the single largest driver of costs and with the advent of the electronic age, this problem has been multiplied.’ With these new Rules placing such prominence on the importance of proportionate costs, we can expect judges to use their new powers and duties to actively monitor and manage costs, particularly when it comes to electronic disclosure. Hence, we should ensure that we are well-prepared for this increased scrutiny on costs, and we should be as pro-active as possible in ensuring that we fully understand not just our new duties under
these reforms, but the opportunities they present as well. Those litigators who consider the disclosure implications in their case early on are more likely to be able to use this new menu option to their tactical advantage. Much has been said and written recently about these reforms, especially the perceived haste of implementation and the lack of wider consultation. Some senior litigators, costs experts, and apparently, even some judges, are predicting that this will be a chaotic and uncertain period for legal costs and funding. These concerns are perhaps not completely unfounded; at the time of writing, and just days after the MoJ first published the amended Rules, Lord Justice Richards, chair of the Civil Procedure Rules Committee, actually announced that there would now be another Statutory Instrument in March, to clarify aspects of the Rules. At the time of writing, a further amendment was announced by the President of the Queen’s Bench Division, which excludes not just cases in the Commercial Court that were previously exempt from the new costs budgeting rules, but all cases with a quantum of £2 million or more issued in either the Commercial, Chancery, Mercantile, Admiralty and Technology and Construction Courts. With less than thirty working days before the 1st April, we await to see what further amendments are going to be announced. For more commentary and opinion on the implications of the Jackson Reforms please visit CCL’s e-disclosure blog, at: www.cclgroupltd.com/EDblog
CASE STUDY Corporate-wide Investigation THE CASE: CCL was instructed by a multinational organisa tion to collect and analyse several ma ilboxes used by specific employees , who the company suspected were passing corporate data to co mpetitors. The relevant individua ls were mobile workers who used their company issued laptop s to remotely access the corporate network on an ad hoc basis. The organisation’s enterprise-wide email system only held the most rec ent email messages and it was thought that the laptops may still hold archived emails of relevance. Th e client’s key requirement was to co llect the data in a covert fashion, in order to avoid false accusations and reputational damage. Therefore, any significant changes to the user’s computer system or its operatio n during collection could alert the user and thus hinder the inves tigation. WHAT CCL DID: In ord er to provide the custome r assurance that the investigation could indeed be conducted in a dis creet and unobtrusive manner, CCL’s analysts initially created a sim ulation within a test laborator y network to demonstrate to the clie nt that the relevant data could be collected and analysed without alertin g the users. This allayed the client’ s concerns, and the investigation continued. THE OUTCOME: CC L was able to identify and collect the relevant files remotely, via the corpo rate network whilst the users where logged in. The logical evidence files were then analysed, and em ails within the relevant period co ntaining keywords of interest were produced for the investigators to review. This approach mean t that all the data required for the investigation was collected in a for ensically sound manner, while ensuring that the users were not dis turbed or alerted. The covert na ture of this investigation also kept disruption to a minimum, allowing business to continue as usual.
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LA
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POTENTIAL SOURCES OF ELECTRONICALLY STORE
Sat Navs Sat Navs vary in the amount of information they hold, some will contain little information while others will maintain a file tracking the devices geolocation over a period of time. This information can be of use where an individual’s location at a point in time needs to be established, for example collusion and competition issues.
File Servers
Mobile Devices
Second to email servers, file servers are the next most frequently relied upon source of information in e-disclosure. Most organisations enforce some degree of central archiving and while files, more often than not do exist on individual’s assets, proportionality often leads to the file server being the main source of unstructured data.
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BI Systems
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Like mobile phones, mobile devices are becoming more relevant to e-disclosure and digital forensic cases. In particular, tablet computers are increasingly being used in the workplace, and at the same time both their capabilities and capacity are expanding.
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Laptops and desktops are almost always potential sources of relevant unstructured data and archived emails. Examination of these devices is not always necessary if the IT policy prevents data from being stored locally. On a technical level, laptops and desktops are virtually identical, the added complexity for laptops arises in the collection phase, ensuring that the devices are in the right place at the right time for imaging.
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Business intelligence systems collate information from multiple parts of the business and can be a useful source of quick analytics.
Removable Media
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Many organisations prevent users from writing data to removable media such as USB sticks, external hard drives and CDs/DVDs. In situations where this is not enforced it is almost always worthwhile including this in the scope as this comparatively inexpensive step often yields worthwhile results.
Timekeeping Systems
Timekeeping systems can be used to build up a profile of an employee’s work patterns. For example, identifying ghost employees or evidencing overtime manipulation.
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Manufacturing Systems
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These systems often hold useful information on a user’s activity. They can be used to establish when a user connected to a network as well as where they connected from.
There is a huge range of manufacturing systems in use, no two of which will be implemented the same. Some systems may hold structured information on stock, throughput and employee activities. Some may hold no data at all.
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A significant proportion of e-disclosure projects will involve hard copy documents to some degree. Relevant hard copy should be scanned, documents passed through an OCR (Optical Character Recognition) process and fed into the e-disclosure platform for review.
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Firewall & Security Logging Systems
Hard Copy
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Backup and Disaster Recovery systems are sometimes overlooked however can be a critical source of information. A restore of an historical backup will provide a snapshot of what information was available at a given point in time.
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CRM
Email Servers
CRM
In the majority of organisations email accounts for the bulk of internal and external communications. As such more often than not, the data extracted from email servers become the cornerstone of e-disclosure projects.
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Customer Relationship Management systems hold a significant amount of sensitive information which could potentially be of great value to competitors. We have seen a number of investigations where information has been leaked from these systems.
Mobile Phones
ERP
Historically, mobile phones have not been widely used in e-disclosure and digital forensics outside of the public sector. As the article on page 6 explains, this could be changing in the not so distant future.
Enterprise Resource Planning systems hold a wealth of information both about the business’s operational activity and back office function. Data analytics of ERP systems is often used to support e-disclosure and digital forensics investigations.
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CASE STUDY Counterfeiting olved THE CASE: This case inv ntity ide e fak of e tur the manufac ng. The cards and human trafficki tion iga individuals under invest ies, tor fac ID were operating fake feit ter un co y alit producing high qu s, nce lice g vin passports, dri n cards Home Office immigratio mputers and utility bills. Various co re we es and USB storage devic L CC to seized and provided for investigation. s The main challenge in thi y of wa a ing op vel de s wa case e of um vol presenting the large in ial ter ma relevant evidential sily ea be uld a format that co in court, reviewed and presented used by and which could also be s. other interested partie the WHAT CCL DID: During cessary ne s wa it sis forensic analy es to process various file typ e rag sto the m fro ted extrac into a m devices and convert the w and vie to sy format that was ea were les fi se the of analyse. Some lised uti en oft y the t tha complex in ich wh can layers or pages, each of ich could have graphic content wh It was e. cas be significant to the out ip str to y therefore necessar ng alo it t sen pre d each layer an t and en cum do e let mp with the co its metadata. to CCL’s R&D team was able mputer co d ne sig write specially-de cess, pro s thi ate tom scripts to au uld wo at wh g isin standard and otherwise be a complex laborious process. ulting THE OUTCOME: The res an d rise mp co presentation with electronic webpage report es all relevant graphic imag image converted to a common ndard sta t tha format; something t be no uld wo re forensic softwa ce. du able to pro ll The productions were we the d an nt, received by the clie s thi on ed op vel scripts CCL de e tim th bo nt clie the case saved L CC ult res a As y. ne and mo red became the client’s prefer es. cas t supplier for counterfei
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LEFT TO THEIR OWN DEVICES – HOW WILL BYOD AFFECT E-DISCLOSURE? By Rob Savage The number of employers implementing Bring Your Own Device, or BYOD policies, is increasing. A recent Gartner survey estimated that by 2016, 80% of all employees will be permitted to connect their own laptop/mobile phone/tablet computer to the corporate network for work purposes. The uptake of BYOD is being driven by potential cost savings and convenience, as well as indications that a BYOD policy actually increases employee productivity by blurring the lines between work and personal life. This blurring is however, a double-edged sword with many potential legal and technical ramifications that could cause serious problems for employers, litigators and e-disclosure practitioners. Historically, mobile devices have not been a major source of disclosable information. This is often due to the fact that employer issued devices replicate emails with the central server, and have very limited file creation/storage/distribution capabilities. Therefore, all devices issued and managed by the IT team usually store all relevant information on the device as well as the central servers. Could the same assumption be made with equal confidence for a mixed population of user-owned devices? Possibly not. There are also privacy concerns to take into account. Should an employer wish to investigate a company owned device, they need only request it from the employee. Given the device represents company property, the employee has very little recourse to refuse. It is not so simple under BYOD. Not only does the employer not own the device, but it may also contain significant volumes of personal data, photos, emails, text messages and contacts. Should the employee refuse to hand over their device, a non-party disclosure order could be made. However this will likely have significant cost and time implications, especially where multiple custodians are involved. Assuming that relevant devices have been identified and the custodians have been compliant in handing over their devices, a practitioner now has a number of technical hurdles to overcome when extracting relevant information: • A diligent IT policy will require users to password protect their devices. Password protection on some devices can be subverted, but on some it cannot. Successful recovery of the data may require the custodians to also hand over passwords. • It is possible that the practitioner will then face a myriad of different devices and native applications, each with unique file systems and storage methods. The practitioner will need to have a broad range of tools, technology and techniques at their disposal to successfully complete the exercise. In summary, e-disclosure across a BYOD population of devices is possible but not straightforward. User-chosen devices are a potential weak point for an organisation and any proactive steps to limit what data can be stored/created/distributed using these will help. Organisations adopting BYOD need to have processes and procedures in place that can ensure access to the devices to facilitate investigation, or face the prospect of slower, more costly e-disclosure.
DBAs – DON’T BOTHER AGREEMENTS? By Umar Yasin The rest of the world knows them as contingency fee agreements; upon their introduction to the UK, Lord Justice Jackson has renamed them damages-based agreements, perhaps to avoid confusion with another funding acronym: our old friend, the CFA. CFAs, conditional fee agreements, still survive post-Jackson, albeit with ATE premiums and success fees no longer being recoverable. Contingency fee agreements have always been available for noncontentious work; DBAs are now to be allowed for civil litigation too. Jackson recommended the adoption of the ‘Ontario Model’: a model of damages-based agreements that exists in the Canadian province of the same name. What this model essentially means is that lawyers acting on a DBA must set-off, pound for pound, all costs recovered from the other side. On the face of it, DBAs are perhaps the purest and strictest way of achieving true proportionality in a case, as all interests are squarely aligned. The Damages-Based Agreements Regulations 2013 has now been produced by the Ministry of Justice. Whilst confirming that the Ontario Model is indeed the one to be adopted, the regulations also contain some surprising implications, aside from the fundamental implication the Ontario Model itself creates. The first surprise is that there is to be a cap on the proportion of damages. This is already the case in employment tribunal cases, where DBAs are already allowed, and where lawyers can only take a maximum of 35% of damages. However, it was widely expected that there would be no such cap in commercial cases. Indeed, the Civil Justice Council had originally recommended a tiered approach to commercial cases; it identified three categories of cases. The first involved businesses, the second consumers and the third involved small businesses with less than 10 employees. It suggested no cap for commercial cases involving businesses with more than 10 employees, as such cases were ‘likely to involve sophisticated purchasers of legal services entering into contractual arrangements where freedom of bargaining should not be inhibited.’ The Working Party was split as to whether there should actually be a cap
for commercial cases falling under the other two categories, but agreed that were a cap to be introduced, it should be set at 50% of damages. Instead, the regulations include a 25% cap for any DBA entered in respect of personal injury claims. They retain the 35% for employment claims and introduce a 50% cap for all commercial claims, without making any of the distinctions that were recommended by the Civil Justice Council. The second, and perhaps most surprising implication is that the regulations, read as they are, seem to preclude part-DBAs, or discounted DBAs, such as discounted, or no-win lower-fee CFAs that are commonplace currently, especially for commercial cases. I have read and re-read the regulations, and have heard some of the views expressed about the way clause 4(1) is drafted, and I agree that we could certainly do with some clarification from the MoJ before the 1st April. Read as it is, the regulations are ambiguous, in that they do not definitively seem to preclude part or hybrid DBAs. Of course, the true test on this point would be clarification on a live case, but I cannot imagine many firms willing to risk testing this proposition, as a failure to comply with these regulations would render the entire DBA unenforceable. Adoption of the Ontario Model means lawyers must give credit for all recovered costs, which will then be deducted from the amount charged to the client by way of the contingency fee. This also raises a key question and has implications for the attractiveness of DBAs to lawyers; why would a lawyer enter into a DBA, where a CFA would usually be much more attractive? With a traditional conditional fee agreement, where costs would also be recoverable from the other side, a lawyer acting on this basis with a success fee would be better off than acting on a DBA, where he would have to set-off recovered costs first. So, on the face of it, in circumstances where lawyers can act on a conditional fee, with a success fee, this will always be a better option, rather than acting on a contingency fee in the same circumstances. Indeed, this point is something that Lord Neuberger has also pointed out; ‘Some have already argued that there is little incentive for solicitors to act on DBAs in circumstances where they
could act on a CFA.’ However, Lord Neuberger also made a valid point about the availability of DBAs having the effect of increasing competition, as although a DBA may be unattractive to a solicitor, it may well be very attractive to the client. In this case, where the client is inclined towards a DBA, the solicitor that offers CFAs as well as DBAs will have a competitive advantage over the solicitor that is only willing to act on a CFA. As Lord Neuberger put it, ‘the brave new world of DBAs may well help to encourage a more genuinely competitive marketplace, in which solicitors are having to become even more clientor consumer-focused.’ So there we have it – DBAs are now allowed for contentious work, due to the enactment of section 45 of the Legal Aid, Sentencing and Punishment of Offenders Act 2012, and the statutory instrument recently laid out in Parliament brings section 45 into effect from the 1st of April 2013. It remains to be seen how attractive DBAs will be to solicitors, but one thing is for sure; it will doubtless be attractive to many clients, from multinational corporations to feuding Russian oligarchs. Therefore, lawyers will have to carefully consider when DBAs will be appropriate, and I have a distinct feeling that we will only see real use made of DBAs in high-value commercial disputes that are likely to settle early on. For the vast majority, the initial view on DBAs does seem to be that they mean ‘don’t bother at all.’
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ABOUT CCL CCL is the UK’s largest digital forensics laboratory, and a leading provider of e-disclosure and IT consultancy services. From our beginnings as an independent IT consultancy in 1986, we have developed our services to respond to advances in new technology, the increasing importance of data, and the need to manage, recover and protect it. In 2001, we setup our digital forensics laboratory. CCL is now the largest digital forensics provider in the UK, and the only one to hold the ISO17025 standard for our computer, mobile phone and SatNav laboratories. CCL has been in the e-disclosure market since 2009 and to date has completed over 200 e-disclosure exercises. OUR SERVICES:
COMING UP NEXT MONTH:
• e-disclosure • Digital forensics -
All operating systems Smartphone/mobile phone Tablet SatNav analysis Cell site analysis CCTV analysis
• Collections • Expert witness
• What you need to know to survive under the Jackson Reforms • Predictive coding - the future?
THE NUMBERS CCL employs over 100 full-time members of staff, including 65 consultants and analysts who have completed: • • • • • • •
200+ 2,500+ 50,000+ 350+ 2,000+ 700+ 450+
e-disclosure cases digital forensic (PC) cases mobile phone cases cell site cases consultancy engagements legal and defence cases expert witness assignments
For more information call Rob or Umar on
01789 261200
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email edisclosure@cclgroupltd.com or visit: www.cclgroupltd.com
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