Consulting Association: the destruction/concealment of documents – testimony of an insider

Ian+Kerr+

Ian Kerr

One of the testimonies given at the Construction Industry Vetting Information Group Litigation court hearings, earlier this year, was that of Mary Kerr, the wife of the late Ian Kerr, who was a leading figure in both the Economic League and, after its demise, the main organiser for the Consulting Association. That testimony – which is given in full below – offers an insight not only into the day-to-day operations of the Consultancy Association, but also what happened to the blacklisting files and other evidence. In section 10 of the testimony Mrs Kerr confirms that ‘back-up paper copy record cards’ were retained by her husband after the raid by the Information Commissioner’s Office and how the ICO failed to remove the (approx. 800) “green and pink record cards” of animal and environmental activists. She also confirms how the Consultancy Association files – together with those from Caprim Ltd – were all sourced from the Economic League trove (which is estimated as being around 30,000 names).

(Note… Ian Kerr was a former private investigator and had been involved in blacklisting for more than 30 years. Michael Noar, the Economic League’s director-general between 1986 and 1989, said Kerr had worked for the organisation for a long time, infiltrating “a lot” of trade union and political meetings, recording who had said what and taking away documents such as attendance lists. Here is a copy of Mr Kerr’s oral evidence to the Scottish Affairs Committee: Blacklisting in Employment, shortly before he died. More on the Consulting Association – via a report by the Scottish Affairs Committee – is here.)

A. Introduction

Mary Kerr’s testimony details:

a) how Economic League files were transferred – “sold” – to the Consultancy Association and Caprim Ltd;
b) how David Cochrane retained copies of 500+ blue and orange cards (pertaining to Economic League records) prior to the ICO raid;
c) the background to the infamous Consultancy Association meeting at which Gordon Mills, the National Extremism Tactical Co-Ordination Unit officer, spoke;
d) the role of Callum McAlpine, the eminence gris and former Chair of the Consultancy Association and who represented the construction firm Sir Robert McAlpine Ltd;
e) confirmation that Consultancy Association client companies expected Mr Kerr to ‘play ball’ and take the blame for everything;
f) and how Sir Robert McAlpine Ltd secretly paid the fines and other costs levied against Mrs Kerr’s husband.

(See also Blacklister admits destroying Consulting Association evidence; now has own vetting service.)

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Cullum McAlpine

B. The testimony by Mary Kerr

1. Economic League

The Economic League operated on a much larger scale than the Services Group and the
Consulting Association and covered all industries, not just construction. There were six
regions in the Economic League, each with a definite hierarchy under a regional director.
From what Ian told me, references were held in the same way but the information for the
Economic League was generally sourced internally by the Economic League employees
themselves.

On the retirement of Peter Thackeray. Ian was given the post of Co-Ordinator for the
Services Group. His role was to receive information from HR and IR managers of large
construction companies about individuals who had disrupted the running of construction
projects by acting outside official channels, acting against union directives or as a result of
criminal acts (theft, violence, intimidation of other workers) or, in some cases, as a result of
alcohol and substance abuse. Ian was also responsible for reading out to the named
contacts at the member companies the information that was already held on a record card
about a worker so that the company could decide whether to employ, not employ or employ
but “note and monitor”.

The construction industry generally had recruitment difficulties because sites were set up
from scratch all over the country and it was often difficult to take up references. The record
cards held by the Services Group were not “references” in the usual sense of the word, but
they did enable construction companies to make an employment decision based upon the
risk for an individual to disrupt a project.

Most of Ian’s time was taken up reading articles in the press about topics that might be of
interest to Services Group members. Ian travelled around the country to various anarchist
bookshops, as well as reading the far left and right wing press, finding out as much as
possible about the problems construction sites might encounter. In addition, he monitored
proposed employment legislation which was likely to affect the industry, he kept up to date
with which full-time trade union officials had moved positions and he reviewed what issues
or agendas particular trade unions wanted to pursue. Ian also collected mainstream press
articles that were of interest to the construction industry — relating to unions, legislation,
court decisions and specific construction projects – and these were copied and sent out to
members in mailing lists.

2. Consulting Association

However, the Services Group members had become increasingly concerned about the
future of the Economic League by the early 1990s and held a number of meetings in 1992 to
consider setting up an alternative group. As a result, at some point in late 1992, Ian was
asked by the steering committee of what was to become the Consulting Association to
remove the record cards from the Thornton Heath offices of the Economic League and take
them to the Economic League’s Birmingham office where Ian was based. Ian was also
offered the post of director of the soon to be established Consulting Association and he was
asked to look for suitable premises (which he found in Droitwich).

In parallel, Jack Winder, one of the directors of the Economic League, had discussed with
Ian the impending winding-up of the Economic League from the beginning of 1993 and he
had confided to Ian the day in April when the Economic League would cease trading. Ian
was sworn to secrecy by Jack Winder, who instructed Ian to leave his Economic League
leased car in a pub car park, with the keys in the boot, on a date in early April 1993.

Ian removed the record cards from the League’s Birmingham office the day before the
Economic League was wound up. The cards were then “sold” to the Consulting Association
for £10,000 by Jack Winder and Stan Hardy, albeit they had previously been the property of
the Economic League, as a large proportion of cards had originated from the Economic
League itself, rather than the Services Group.

Ian believed that Jack Winder and Stan Hardy took the remaining Economic League cards
(for those industries other than construction) and used them with their own company,
Caprim Limited; hence, Jack Winder’s request a few months later for any spare plates for
the Rotadex filing system that had been used to house the quick reference check cards
used by the Economic League and the Services Group.

There was a gap of about a week or so while Ian set up the Consulting Association offices in
Droitwich and while he purchased stationery, office supplies, a copier, telephone, fax
machine etc. Ian also transferred the record cards to the Consulting Association’s offices.
where they were initially kept in the drawer of a tall grey padlocked metal filing cabinet.

In addition, Ian transferred to the Droitwich office the quick name checking system – called a
Rotadex. This was a very old rotating system of metal “plates” which alphabetically housed
rows of narrow strips of card. Names were typed onto these narrow strips together with
dates of birth, NI numbers, trades and areas, and the strips would be slotted in or removed
from the Rotadex. These were used to check against names telephoned or faxed through by
members to determine whether there was any underlying record card for a particular name.
Only if there was a name on the Rotadex would the relevant record card be taken from the
metal filing cabinet.

3. Monodex

From the outset, the various member companies would either telephone, or more usually,
fax a list of names to the Consulting Association for checking against the record cards.
However, the quick check Rotadex system was not only large and cumbersome to use as a
quick reference checking system of the faxed names, it was also difficult to update easily.
because it meant having to move down name cards whenever there was a new insertion or
move name cards up if a name was ever removed from the system.

As a result, from about 1995, the names on the record cards began to be typed up in
alphabetical order on to A4 sheets and these were then held in a smaller plastic “Monodex”
filing system so that it would make the initial checking task easier. “Monodex” was the trade-
name for the filing system and this not only saved space and was much easier to use and
move than the large and heavy Rotadex, but it also meant that the list of names could be
updated more easily as only the sheets for a specific letter of the alphabet needed to be
updated and re-printed before being replaced on the Monodex. This process of transferring
the names to the Monodex took about a year or so given that it was only done by Lucy on a
typewriter in her spare time at the office.

In addition to the Monodex itself, there were also two identical copies of the alphabetical list
of the names on the Monodex which were kept in white plastic ring binders (with each page
in a clear plastic wallet). One copy was kept at home and the other copy was kept at the
office so that Ian could use it in his room if nobody else was in the office or it could be used
by Lucy at home (where she would also forward the fax and ‘phone lines) whenever the
office was not staffed (during holidays etc). Each time the relevant sheets for the Monodex
were updated by being re-typed, the same sheets would also be updated in the two ring
binders.

However, the typed sheets were still relatively slow to update on a typewriter – because if a
name had to be added or deleted – the relevant page or pages also had to be retyped. This
was why, in about late 1997, the names began to be transferred on to a floppy disc (and
later a USB stick), so that the document could be updated on a computer and the relevant
pages printed off, with only the single name being added or deleted as relevant — before the
revised pages were printed off and inserted in the Monodex and both ring binders. When a
sheet was updated we would normally record the date of the update in the top right corner
of the page (both for the Monodex and the two white ring binders). This updating process
took some time; for example, it had only reached the letter ‘P” or ‘Q” by the time I started
work in the office in June 1998.

The Monodex and one of the two ring binders containing the same list of names were both
seized by the ICO in February 2009. The other white ring binder duplicate copy of the
Monodex was kept at home and it was later destroyed by Ian with the other papers after the
Crown Court proceedings had finished, on the basis that the ICO already held the original
Monodex and the other duplicate ring binder list.

Every name on the Monodex would have a record card, albeit a significant number of such
record cards either (a) contained no information about the individual, other than the initial
information put on to the record card at the outset. on the basis that such names were not
subsequently accessed by members or (b) contained very anodyne and old information
about an individual. When such names were contained in a faxed list of names sent by a
member company (which was very infrequent), given that the record card contained no
substantive information on the individual, Ian invariably “cleared” the individual to the
member company — as there was nothing to say.

The Monodex was typed up with individuals’ names in different colours, as Ian confirmed to
the Scottish Affairs Committee:
• Black – related to individuals with industrial relations issues and formed the bulk of the
names on the Monodex;
• Pink/Red – related to animal activists;
• Green – related to environmental activists;
• Blue – related to old record cards originating from the Economic League era which
generally were either anodyne (in terms of having no real information about an individual’s activities or any complaints) or had missing identifying information on the
individual; and Orange — these generally related to EPIU members (where the majority of the names had been provided in about 1992), but where there was no substantive information on
each of the individuals, except his EPIU membership and frequently where at least
some of the identifying information was missing (eg: either NI number, date of birth or
trade).

In practice, the only names that were ever referenced to member companies were the black
names on the Monodex.

As I have stated above, when the record cards were brought over from the Services Group,
they were originally kept all together in the drawer of a tall grey metal padlocked filing
cabinet in the Droitwich office. Ian subsequently grouped the record cards by colour and in
alphabetical order. The colour used for the names was down to Ian alone and was
designed to ensure that the record card for the relevant individual could be found faster and
more easily from within just those cards for the black names rather than having to search
through the whole body of record cards — blue, orange, pink and green. However, this was
purely for internal administration purposes and. as far as I can recall, Ian did not mention
colours to member companies when a name was picked up. The names were originally
coloured by Ann or Lucy with a marker pen on the Monodex (and the two ring binder lists),
but once the Monodex was transferred to a floppy disk, we changed the colour of the
typeface on the computer.

I can clearly picture the positions of the record cards in the filing cabinet drawer. There were
about three complete rows of record cards for the black names, there were then the blue
cards banded together at the back of the fourth row and the cards for the orange names
were also banded together at the front of that row. The two JLE Lists of names (see below)
were simply banded together and placed at the front of the drawer.

The record cards for the pink and the green names were mostly produced after I began
working at the Droitwich office in 1998, as I can recall personally typing up a large number
of their record cards. These record cards were created because it was feared that activists
may seek employment on some of the contentious sites in order to disrupt the works but, in
practice, they were not flagged up and the cards were stored separately in the safe to avoid
them getting lost.

When the cards were sometimes taken out of the filing cabinet drawer and kept in a
cardboard box (for ease of transporting them around), the record cards for the blue and
orange names were each still kept banded together to keep them separate from the record
cards for the black names on the Monodex.

The cards were kept in cardboard boxes so that they were portable when we were on
holiday. In addition, in late 2007/early 2008, after Alan Wainwright had blown the whistle in
the Steven Acheson tribunal proceedings, the cards were transferred to two boxes so that
they could be taken back to our house to keep them secure overnight. However, this system
just wasn’t practical and so the cards were taken back to the office. The two boxes of cards
were stored at the bottom of the padlocked metal cabinet rather than being replaced in the
drawer. Overnight the plastic Monodex was stored on top of the boxes of cards whilst the
white ring binder copy of the Monodex was kept in the safe.

I understand that the 100 has no, or only very few, record cards for any of the coloured
names. I can easily explain the absence of the record cards for the pink and the green
names because, as I have stated above, these record cards (I understand about 813 in
total) were kept in the safe at the office, on the basis that, although there had been concerns
that these individuals would seek to disrupt sites from within, in practice they were not
accessed.

However, I cannot so easily explain the absence of the record cards for either the blue or
the orange names. I understand that these account, in total, for about 557 names (about
177 blue and 380 orange). The record cards for both the blue and orange names were each
kept banded together but with the main body of the record cards for the black names – either
in the filing cabinet or the cardboard boxes – and I thought they were still there up to the
date of the ICO raid. They would, therefore, have been taken away by David Clancy.
However, I understand that the ICO do not have such record cards.

Sometimes record cards would be taken from the main body of cards for review by Ian —
generally on the grounds of the age of the individual. Whilst being reviewed, Ian would store
such cards each night in the safe at the office, together with those other record cards where
he was awaiting a response from a member company following a match (or “pick up” as we
called them) of names. However, there would only have been a very small number of such
cards in the safe each night and this cannot explain the absence of the blue or orange
names from the record cards in 2009.

Consistent with this, I am told that there are a number of names in black on the Monodex list
which have no underlying record cards. I cannot be certain, but I would be confident that
most of those names did have record cards but that such cards were either “out”, most likely
being considered for removal by Ian (based on their age) or, less likely, they were ‘out”
while Ian awaited responses from member companies at the time of the ICO raid in 2009.

I had broken my leg shortly before the ICO raid and I had not gone into the office for about a
week before the ICO raid. It is possible that Ian may have removed the record cards for the
blue and orange names from the cardboard boxes in that week leading up to the ICO raid,
simply for ease of transport and because, after 16 years, he knew there was an almost zero
likelihood that such blue and orange names would be referenced by a member company.
However, he never mentioned this to me at any stage and I am not sure where else he
would have put these record cards as they would not have fitted within the small office
safe.

The cards for the blue names on the Monodex list were all banded together and kept
separately from the cards for the black names because they generally related to individuals
with almost blank or at most, relatively bland and old record cards from the Economic
League era. These cards were all particularly old and grubby and they were not referenced
(almost certainly because of their age and their lack of relevant details). Hence, these
names stayed blue and the record cards were stored held together by elastic bands in a
separate row to those record cards for the black names.

Record cards for individuals which did have something substantive, or which Ian considered
could be of potential relevance in future, even if old and from the Economic League era
would have names printed in black on the Monodex. The old Economic League cards,
where the names were in black rather than blue on the Monodex, would have been
regarded by Ian as those with at least still some potential to cause disruption on a site
(either because of the number of referrals or the type of comment). However, Ian generally
tended to stress the age of any information when speaking to the member companies about
a particular individual.

During the time of the Consulting Association, blue names would have been changed to
black on the Monodex if any relevant information was later added. However, for names
which remained blue, there would have been no information provided or any action taken
after 1993. I personally cannot recall any blue names being changed” to black on the
Monodex as a result of any later added information.

At most, I can recall only about one or two occasions that any blue name was flagged up
following a list of names being faxed through by a member company and on both occasions
Ian gave instructions to clear the individual because the information was so historic by that
stage. In both cases, the member companies were not told that there was any record card
held on the individual.

Similarly, the vast majority of the orange cards contained only an individual’s name, trade
and/or their particular area; they did not contain any information on the individual except to
say in almost all cases that he was a member of the EPIU. The majority of such record
cards were missing full identifying details — such as NI numbers or dates of birth (which Ian
saw as essential in order to make a positive check). I am not aware who provided the
majority of the orange names, albeit, I understood from Ian that they had been provided in
bulk in about 1992/93 (before my time working with Ian).

During my time at the office, I can only recall about one or two orange names being flagged
up but neither had full identifying details and so both were cleared by Ian (as Ian did not
want someone to be affected simply on the basis of mistaken identity). The record cards for
the orange names, although being around from 1992/93, looked far newer and far cleaner
than any of the other cards — reflecting their lack of usage. This is also, I think, what Ian was
referring to when he said to the Scottish Affairs Committee that “I have a feeling that those
cards hardly ever came back up through the system” and “The question of the EPIU didn’t
crop up in an awful lot of cases”.

That is also the, same recollection of Lucy, who worked at the Consulting Association until
the ICO raid in 2009. She has told me that it was very rare for such orange names ever to
be referenced and, as such, she also recalls that the cards for the orange names were
relatively new looking, given their lack of usage. Lucy also recalled that Ian generally
cleared the isolated orange names that were flagged up without revealing to the member
company there was a record of the individual, where there was a lack of full identifying
details and a lack of any substantive information on the individual.

4. Checking Process

I or one of the other employees would check the list of names faxed over by a member
company against the Monodex, ticking all names on the fax which were not on the
Monodex. One of us would then always call the member company to say whether the list
was “clear” or whether there had been any matches or pick ups. We would call the
designated individual who sent the list at the company to confirm this. For example, we
would say, “Of your fax of 13, all clear’ or “Of your fax of 13, all clear except NAME”.

If a name was listed on the Monodex, we would locate the record card and provide it to Ian
together with a photocopy of the list of names that had been faxed from the member
company. Ian sat in an adjoining room and he would then call the designated Main Contact
at the relevant member company, he would confirm the name of who had been flagged up
and he would then read out, pretty much verbatim in most cases, the contents of the record
card. Ian would only call the Main Contact at a member company to inform him or her of the
content of the relevant record card.

Ian would record what the Main Contact had said on a separate slip of paper, which also set
out the company reference number and the main contact initials and he would clip this slip
to the record card. Sometimes, the Main Contact would give an immediate answer as to
whether the individual was to be taken on or not. When the Main Contact had to consider
the position, Ian would store the card and the slip of paper in the safe at the office, awaiting
their comments. During this time, we would insert a place holder card in the alphabetical
record cards for the black names stating “Card Our to indicate that Ian was awaiting a
response.

Ian would then pass to one of us the original record card and the slip of paper on which he
had recorded the Main Contact’s response. It would be our responsibility to type up the card
to record exactly what Ian had written, before giving it back to him with the slip of paper for
checking. Only after Ian had confirmed that the updated record card was accurate did we
return the updated card to the main body of record cards.

We would also take a photocopy of the updated record card and insert that updated copy in
to the paper set of copy record cards that Ian kept at home. Ian kept such a parallel set of
paper copy record cards in case anything were ever to happen at the office — such as a fire
or a flood – to prevent the whole database being lost.

Ian was meticulously careful and methodical in his job (and in life generally) and he would
scrutinise the typed-up record card to ensure that it did accurately record what he had
written on the slip of paper. There were a number of times where we were required by Ian to
correct an error. For example, I can remember spelling “Paternoster’ wrongly on a group of
record cards and having them returned to me by Ian for correction. I also recall having to
correct “3223/n” for “3223/m”.

No other information was referred to when checking the names sent by fax by member
companies. The names were only ever initially checked by us against the Monodex and.
only if there was a match/pick up, did Ian look at the record card for that individual. Neither
Ian nor Lucy, Charlotte or me referred to any other documents when checking individuals.

I can be confident in stating that, from June 1998, all positive matches/pick ups were
recorded on a card. The same is also very likely to be true from 1993 because Lucy was as
meticulous as Ian and she was totally reliable.

As I have stated above, there were also two other lists of names entirely separate from the
record cards — which I have been shown and which I am told are referred to in these
proceedings as the “JLE Lists” I cannot now recall who originally provided Ian with the JLE
Lists. However, we never checked against either of these JLE Lists in addition to or instead
of the Monodex or the record cards.

The majority of the names on the JLE Lists did not have record cards and so they were not
recorded on the Monodex. As a result, although the JLE Lists were kept in the filing cabinet
with the record cards, they were not used, as it was the Monodex that dictated whether a
name on a list sent by fax by a member was identified as having a record card and, if so, we
would simply then refer to that record card. If a name did not appear on the Monodex, that
was the end of the matter, no further checks or research or enquiries would be undertaken
and the individual would simply be -cleared” There was no additional relevant information
about any individual on the JLE Lists — just that they had worked on that particular project.

The two JLE Lists were simply retained in the same place as the record cards for convenience, but they were not accessed. The only time I recall that Ian looked at the JLE Lists in any detail was following the publication of the list of names by Alan Wainwright on his blog, when Ian cross-checked Alan Wainwright’s list against the JLE Lists.

Ian had initially wanted to create a record card for each and every name on the JLE Lists,
because he had been told that a lot of applicants to sites were leaving off any connection
they may have had with the JLE project on their application forms. However, Lucy and I
were opposed to this, simply because of the time it would have taken to type up such a
number of record cards. Ian, in time. agreed that there was no point, given there was
nothing he could substantively say about the majority of the individuals and, in the end, only
those individuals that were identified by the member companies to be “leaders” of the
dispute had record cards produced and had their names put on the Monodex.

In other words, if a person’s name appeared on either of the JLE Lists, but did not appear
on the Monodex, they could and would never have been checked. A worker needed to have
his name on the Monodex in order to be checked and for Ian to pass on the information on
the record card to a member company.

As I have said, Ian was meticulous and, in addition, the number of positive matches/pick ups
during a month was nearly always low. On average, I would estimate that there were, at
most, only 8 or so pick ups per month. In some months there could be up to 12 pick ups, but
more frequently there could be none or perhaps just 2 or 3 per month.

For example, I have been shown the total quarterly usage figures for October to December
2008, which show a total of 6,266 searches across all members in that quarter (2,751 in
October, 2,233 in November and 1,282 in December) but which indicate that there were
only a total of 8 picks ups in the quarter (4 in October, 3 in November and 1 in December).
Similarly, the total quarterly usage figures for April to June 2007 show 9,605 name checks
but only 19 pick-ups, whilst in the following quarter (July to September) there were 10,154
checks and only 24 pick ups.

As I have previously stated to Phil Chamberlain when he visited me to discuss the book
“Blacklisted’, one felt a small “bolt of adrenaline” (page 158) whenever there was a positive
match, because it was such an infrequent event. especially in comparison to the large
number of faxed names we had to check each month.

As such, it was not a case that we were overloaded with names so that positive
matches/pick ups would slip through the net or would not be recorded on the cards. Every
application for work relating to an individual with a record card that was checked through the
Consulting Association appeared on a record card — unless the card was almost blank (such
as for the orange names) or very old and with no relevant information (as with the blue
names) where Ian, therefore, simply cleared the individual.

As Ian stated in his written evidence to the Scottish Affairs Committee (and as he set out for
the journalist Billy Kenber), on average each year, there would be about 40,000 names
referred by the member companies of which, only about 100 would ever be ‘positive”
(picked up). Of those, “positive” matches, Ian thought that perhaps only about 50 or so
would ever result in the member company deciding not to employ the individual.

For Ian, the whole rationale of the operation was to keep an up to date and accurate record
of the positive matches/pick ups. Updating the cards was our priority — otherwise, the
operation would have been relatively pointless and the member companies would have
been justified in complaining that the information was out of date or inaccurate. This would
have been unacceptable for Ian and he would have made sure that everything was as
accurately recorded as possible.

The process was simple; if a name on a fax matched a name on the Monodex, the relevant
record card would be accessed, the Main Contact would be given the information on the
record card and then the record card would be typed up to confirm what action, if any, had
been taken by the member company. The record cards were accurate in terms of recording
positive matches/pick ups and, if a card did not record a positive match, I am confident that
there was no such enquiry or, at the very least, no information was ever passed on to the
Main Contact about the individual.

5. Addition of Names

Member companies would also provide names and details of individuals to be added to the
Monodex. The names would only ever be added by Main Contacts and would be given to
Ian direct; they would not be faxed to the Consulting Association.

Names were to be added by Main Contacts where the individual concerned was considered
to pose a threat of disruption to a site on the basis that he had been involved in activities
designed to cause problems or unrest on sites or where there was or had been any reported
intimidation, violence or criminal activity on a site.

Ian did not receive names of individuals from anybody except the Main Contacts, each of
whom were experienced HR/IR managers. However, he did confirm to me that he thought a
number of names which were referred to him had originated from union officials and been
passed to Main Contacts — especially via Dudley Barrett or Alan Audley.

Similarly, Ian never spoke to or had any contact with the Police or Special Branch regarding
names. The one time Gordon Mills from NETCU (National Extremism Tactical Co-Ordination
Unit) spoke at a meeting was to cover, from what I understood from Ian, the role of activists
and how they tended to infiltrate commercial organisations and cause trouble — which was
clearly a concern for a number of the members working on sensitive environmental projects.
From reading Ian’s notes of the meeting and from what I understood from Ian at the time, this was a general talk to discuss the risks and dangers faced from activists by companies; it
was not a talk about specific individuals and it was not a talk to reveal confidential police
information. From what I can remember, Gordon Mills was initially invited to speak by John
Edwards of Carillion.

6. Group Meetings

In addition to the record cards, Ian also organised meetings around the country – most
frequently in London, the Midlands and the North West – for the various interest groups
within the Consulting Association. These comprised the main Industrial Relations Group, the
Environmental Group and the Healthcare/Facilities Management Group.

The Industrial Relations Group (or Construction Industry Group — shortened to “CIG”) was
the largest group which focussed on industrial relations issues generally within the
construction industry. Although I never attended any of the meetings, from 1998 I would type up the minutes of such meetings from Ian’s handwritten notes.

The meetings would discuss public information about the various relevant site problems, labour shortages, wage demands, trade unions and their officials — in terms of change of positions, appointees, objectives/agendas and disputes.

From what I understood from Ian and from typing up the minutes, seldom were employees discussed, except for the well-known activists where they had written articles or where it was known that they were campaigning at a particular site.

The Industrial Relations Group (of about 40 or so people) would also be sent a mail-out with
a number of press cuttings on a on a fortnightly basis, again based on publicly available
information, which updated them on anything that might have been of interest between meetings.

The Environmental Group used to be called the Wolverhampton Group, as it originally met at Tarmac’s offices in Wolverhampton, before moving its meetings to The Bear in Woodstock, Oxfordshire. This group was focussed on environmental and animal rights activists, in terms of
discussing those projects which were being targeted (such as new roads, runways, tunnels
and laboratories) and the ways in which activists were seeking to disrupt sites, given how
disruptive and costly such protests could be for the construction companies. I recall that
these had included the Manchester second runway, the M11 and the Bath bypass. Again,
the material produced for these meetings was gleaned from the press and collated the
disparate information from around the country. This group of about 20 people would also be
sent press cuttings about once or twice a month, which updated them on targeted projects.

The Healthcare/Facilities Management Group met irregularly and focussed mostly on the
developing and changing commercial issues arising out of PFI projects as well as the
availability of labour and the unions’ positions on specific projects. This group was relatively
small and it was sent a mail-out about once a month.

The mailing lists for the various groups were designated the following letters:
• “0” — The Main Industrial Relations Group (also referred to as the “Main Cuttings list”);
• “R” – The Rail Group:
• “W” – The Wolverhampton/Woodstock Environmental Group;
• “FM” – The Facilities Management Group (PFI hospitals etc); and
• ‘CA List’ – The Main Contacts invited to the AGM/Finance Committee meetings.

The Rail Group did not meet. It was only a mailing list of about 10 members which were sent
information about once a month.

There was also an M&E Group that met from the early 2000s, from what I can recall. This
was not as large as the general Industrial Relations Group and it met about twice a year to
discuss issues specific to the M&E industry.

In addition to the meetings and mail-outs, Ian would also circulate a “Two-Week Note” to Mr
McAlpine, the Chairman, past Chairmen and other senior IR/HR individuals every 2-3
weeks. The note was intended to be a short summary of what disputes, IR issues and union
issues had been going on within the construction industry. It was always in a smaller font to
other documents (9 or 10 compared to font 12 for meeting agendas and minutes) and it was
limited to one side of A4 paper, with the objective that it could be read quickly to bring the
reader up to speed with the bigger issues affecting the industry. Sometimes items from this
“Two-Week Note” were copied and pasted on to reference cards. I understand that these
items (in a smaller font) have been mistaken for minutes of meetings.
Press Cuttings Service

In addition to the referencing service, we would all spend a significant amount of time
preparing the various press cutting mail-outs for each of the groups. This involved cutting
and pasting extracts from the press, which had been found by Ian, on to A3 paper and then
copying them for circulation.

Ian would keep for years up to 5-6 copies of each mail-out in case any questions were later
asked by members and these copies took up a lot of space in the office. Lucy and I would
frequently ask Ian if we needed to keep such mail-outs for quite so long, but he would nearly
always say that it was safer to keep them “just in case anybody asks”.

7. Fees

In addition, I was responsible for keeping the accounts of the Consulting Association and
logging income and expenditure in the Cash Book. The accounts were audited every year
by a Chartered Accountant. I also submitted quarterly VAT returns and prepared the
summaries of income and expenditure for the Finance Committee meetings that were held
twice a year. We all prepared invoices and sent out acknowledgements for payments.

Membership charges were a flat annual subscription charge plus a flat minimum charge per
quarter (£25:00 for the last few years up to 2009). If there were more than a limited number
of checks in a quarter, the members paid an additional fee depending on the number of
names that had been checked that quarter. The intention was to generate enough income to
cover the running costs whilst keeping enough cash in reserve for contingencies.

Most of the time, we would keep all faxes for a period of 3-4 months so that, if there was any
query from a member as to the usage fee, we could confirm the exact numbers by reference
to their faxes. However, by about 2004, such requests had dwindled and, eventually, we
started shredding the faxes from the previous day every morning, but only after entering the
number of names referred in the blue A4 file for each company, rather than shredding them
every 3-4 months. This was essential to avoid cluttering up the office, as until then, the
faxes had been taking up two drawers in a filing cabinet.

The usage fees were calculated on the number of names faxed through by each member
per quarter and we kept a running record — on a daily, monthly, quarterly and annual basis –
of both the number of names that were faxed and also the number of “pick-ups” that came
out of those names. The names sent through for checking would be written down on the left
and the number of “pick ups” would be recorded in brackets on the right (generally in red).

When collating and recording the quarterly usage figures, we would record them in columns
per month based upon the figures which had been recorded each day per company. There
would be two columns for each month — one for names referred and one for “pick ups” (and
headed “P.U.”) and then there would be two columns at the end, again headed Total and
P.U. but under a heading of “CUMULATIVE” and drawing the total numbers for that quarter
for both referrals and “pick ups” together.

Each company would be charged a minimum quarterly flat rate (a “minimum charge” of
£25:00 per quarter by 2004), even if no names had been submitted during that quarter.
There would be no additional fee if a company had only submitted less than about 10 or 12
names in the quarter (ie: within the £25:00 quarterly minimum charge). We would double-
check our figures by deducting the minimum charge figure from the proposed fee and then
dividing the remaining amount by the checking fee per individual.

Frequently, a large number of the members for any quarter would only ever be invoiced the
“minimum charge” of £25:00 because of the low number of names for checking they had
sent through that quarter. For example, I have been shown an invoice dated 1 April 2005
sent to Costain Oil Gas & Process Limited in 2005 which has a “Minimum Charge” of £25.00
and which, therefore, confirms that Costain could only have submitted less than 10 or so
checks during that quarter. The invoice attached the Costain usage figures for that quarter
(copied from the quarterly usage record book) confirming in that quarter only seven
references were made — five between 16 December and 31 January 2005 and two in March
2005. The usage figures also indicate that there were no “pick ups” from these seven
references during this quarter as the columns headed – P. U.” for each month are all blank.

Conversely, the invoice dated 4 October 2004 sent to Costain has a charge of £297.50 —
well above the minimum charge of £25:00 – and this is reflected in the attached usage
figures which show that there were 100 names sent to us in July 2004, 35 were sent in
August and 35 were sent in September. However, again, despite the higher number of
checks in that quarter, there were no “pick ups” as the “P. U.” columns each remained blank.

Again, to indicate the infrequency of pick ups against the volume of names checked, I have
reviewed the monthly usage figures for Sir Robert McAlpine (Code 3239) for the April-June
2007 quarter. These indicate there were 65 names checked in April 2007, but with no pick
ups, 962 names checked in May 2007, again with no pick ups and 970 names checked in
June 2007 with two pick ups. Consistent with this, in the same three months, Balfour
Kilpatrick (code 3223/F) checked 288 names in April 2007, with 1 pick up, 260 names in
May 2007 with 3 pick ups and 279 names in June 2007 with no pick ups. These figures do
not strike me as at all unusual. Indeed, for the October to December 2007 quarter, Sir
Robert McAlpine made a total of 2,160 checks, but with only 4 pick ups and it is likely that
Sir Robert McAlpine would still have employed and monitored these four individuals.

The usage fee records were kept for each company in red A4 files for each year and most
were stored in the metal filing cabinet in the main office. As the shelf filled some of the older
files were stored in a filing cabinet in the corridor between the two rooms. The usage figures
which we recorded for every year demonstrate that. despite the very high number of
monthly or quarterly checks by the member companies, there were only very few pick ups.

8. Documents in the Droitwich Office

There were two rooms within the Droitwich office separated by a narrow corridor.
In Ian’s room would be his desk, the safe (in which the green and pink record cards were
kept), the copy Monodex white ring binder file. a cabinet with a drawer of current financial
year bills, the files for company invoices and acknowledgements for each company, current
years meeting files, historic meeting minutes and agendas, the red book which listed contact details for day to day HR contacts (as they changed over the years) and the blue
book which listed contact details for the Main Contacts, files of copy correspondence. a
drawer of articles on construction projects and boxes of historic mail-outs, old magazines
and newspapers, historic rent bills and receipts, plus old bills for electricity and telephone.

In the other room, would be two desks and a table, the Monodex itself, the computer, the
record cards stored in a filing cabinet, the Sales Day book which recorded all the invoices
sent to the companies, the ring binders on the various trade unions (gleaned from the press
and from union publications) and the red ring binders containing the usage figures for each
company. In, addition, there would also be the photocopier, further old magazines and
newspapers, the fax machine the typewriter, stationery cupboard and shredder. In the
corridor would be a metal cabinet containing some historic files of usage figures and also
boxes of paper and stationery, envelopes and an old photocopier.

The files on the various trade unions would record the area office addresses, current official
positions within the unions and the relevant area full-time officials, based upon what Ian
could obtain from the unions’ own handbooks and publications and from the newspapers.
From what I recall, Ian had files on each of the main construction trade unions over the
years. These files did not contain information about any union officials that did not come
from a public source, they did not contain any information about whether such individuals
should be employed or not and they were never accessed or referred to when a faxed list of
names was sent to us; the information was simply not relevant to those enquiries.

The various files on the higher profile construction projects — such as the Jubilee Line
Extension, the Pfizer Project and the Royal Opera House – would extend back 10-15 years.
These were again general information files, based upon press reports (almost inevitably
those which had been included in the various press-cutting mail-outs) and which set out the
general background information on each project — both in terms of the physical construction
as well as the industrial relations issues. Again, none of these files were relevant to the
checking service and none of these files were ever accessed as part of a record card check.

The cash books, cheque books and documents relating to staff salaries, Ian’s car, pension
and BUPA membership were all kept at home because I updated the accounts from home.

Ian never looked at any documents other than the record cards when discussing names with
the Main Contacts. The mail-outs, project articles and the information on the various trade
unions were general background information to be circulated to the member companies or
to form the basis of discussions at the regional meetings. As I have said, Ian only read out
the record card itself to the Main Contacts after Lucy, Charlotte or I had done the checking
of the faxed names against the Monodex and after we had provided Ian with the record
card. Ian was not provided with and did not consider or discuss any other information as
such general information in the press-cuttings and ring binders did not relate to any individuals on the record cards. Some of the cards had envelopes attached, which contained press cuttings where an individual had been mentioned in a publication or had written an article but I don’t recall ever reading them. Similarly, the two JLE Lists were not accessed by Lucy, Charlotte or me and were never provided to or read by Ian as part of the checking process. The suggestion that Ian had a far greater number of files on individuals which were used to determine whether individuals would be employed or not is completely wrong.

We also kept duplicates of invoices and VAT receipts for many years. Ian was a real
hoarder and it was always difficult persuading him to get rid of anything. For example, we
had several boxes of copies going back a number of years of The Morning Star, The
Socialist Worker and other left wing magazines, simply in case any of the members were to
ask about the contents of a previous edition.

In addition, we had a file called Bring-ups” that we kept in one of the drawers. Every
morning we would work our way through this file as far as possible, between checking faxes
of names, doing mail-outs, sending invoices and acknowledgements etc. It consisted of
invoices that needed acknowledging, items that Ian needed typed up, such as meeting
agendas, mail out items etc. The priority was always to update the reference cards. There
was also a “cards to be done” wallet within the “Bring Ups” file but this was low priority. Ian
kept lists of websites, publications and organisations on a number of cards that he thought
might, at some point, be useful. I can only remember a few such as “Friends of the Earth”,
Earth First”, Reclaim the Streets”, “Huntingdon Life Sciences” and they would only contain
information that Ian had read about in the newspapers.

Towards the end of the Consulting Association, there were discussions about alternative
approaches and whether there should be a more formal referencing service. The concerns
were, in part, because of the Data Protection Act and also, in particular, following Alan
Wainwright’s evidence about the companies’ use of the Consulting Association. I
understood from Ian that the discussions did not reached any conclusion as there were
differences of opinion and because it was felt that, without more staff to undertake a full
reference/CV checking service, such an approach would not be possible.

In addition, towards the end of the Consulting Association’s lifetime, the members began to
discuss Ian’s potential successor and I recall Ian telling me that Murray Reid of NG Bailey
was being discussed as a potential candidate, in terms of his knowledge of the system and
because he was to leave NG Bailey in 2009. However, this did not come to anything, given
the ICO raid.

9. CO Raid — February 2009

I recall the day of the ICO raid in February 2009 as I was at home with a broken leg doing
the Consulting Association VAT return. Ian rang to tell me about the raid and said that it was
probably the last VAT return I would need to prepare, given that the ICO had taken away a
lot of documents and the computer. He told me that the ICO took the Monodex, the copy
ring binder file containing the Monodex list, the computer and pretty much everything that
was “even remotely incriminating”.

Ian told me that he also spoke to David Cochrane, who was the then Chairman of the
Consulting Association, to discuss what should be done next and they both decided that a
meeting needed to be arranged with all the members within the following week or so to
discuss what should happen.

Ian and David Cochrane quickly reached the conclusion that there were really only two
options; either to close down or to continue in another form, having properly registered the
Consulting Association with the ICO. In the interim, Ian and David Cochrane had decided to
stop the operations of the Consulting Association immediately, for Ian to contact all member
companies to confirm that the service was being suspended and for Ian to confirm that no
more faxes were to be sent pending a meeting of the members to decide what to do next.

In the few days that followed the raid, Ian told me that he spent a lot of time on the phone
speaking to the Main Contacts, telling them what had happened and trying to set up the
proposed meeting.

Ian never told me or gave me any reason to think that he and David Cochrane were
considering destroying the Consulting Association documents and no steps were ever taken
by Ian to do so. No decision had been made at that time about the future of the Consulting
Association, whether to continue and register with the ICO or to close up entirely, and so no
decision could be taken about the documents until the members had met. If a decision had
been made to destroy everything following the ICO raid, we could immediately have started
destroying the duplicate set of record cards that we kept at the house and we could have
spent the next few days routinely clearing out the office. This did not happen. In addition,
such a destruction policy would have been somewhat pointless as the ICO had copies of
virtually everything. Ian certainly felt that all relevant documents had been taken by the ICO
and, importantly, all the record cards that were in use had been taken.

Ian discussed with me the same evening the second meeting with the ICO on 2 March
2009, which was also attended by David Cochrane. Again, I did not have any impression
that, as a result of the meeting, any decision was taken to destroy documents in order to
hide evidence or to avoid difficult questions.

Ian had a second meeting with David Clancy on 2 March 2009 at the Consulting Association
offices that was also attended by the then chairman, David Cochrane. The same evening
Ian told with me what had been discussed at the meeting. Again, I did not have any
impression that, as a result of the meeting, any decision was taken to destroy documents in
order to hide evidence or to avoid difficult questions.

During the meeting on 2 March 2009, Ian was informed that he was to be prosecuted for
breaching the Data Protection Act. Ian and I both felt this was very unfair, given that Ian had
merely been an employee undertaking what all of the members had paid him to do. This
also later appeared to be the position of the prosecutor for the ICO, Armena Khan, who
appeared to accept that Ian Kerr (trading as The Consulting Association) was the wrong
person to prosecute, but nevertheless continued with the proceedings. Our sense of
injustice later intensified as a result of the member companies’ refusal to provide any
financial or even moral support to Ian during the process. Indeed, in my view. the members
completely abandoned Ian at this stage, as seen from Ian’s detailed handwritten notes at
the time.

David Cochrane had by far the most contact with Ian during this period and he always made
clear that it was in the best interests of the member companies for Ian to “be in the frame”,
otherwise the publicity would badly hit the companies, including Sir Robert McAlpine.

Ian never openly expressed to anyone that he felt cheated or badly let down, even when
David Cochrane made clear that Ian would receive no financial support for the court
proceedings unless he played ball and looked to minimise any voluntary references to the
companies. For example, in June 2009, I recall that Ian was asked by David Cochrane
whether he was being advised voluntarily to name the companies involved by his solicitor
(Jamie Strong) to mitigate his position or whether he was being required to do so by the
Court. This placed Ian in a very difficult position, as he never wanted to name the
companies, because he said that the Consulting Association had always relied upon trust.
However, at the same time, Ian wanted to avoid the sole focus being on him and his family.
It made for an exceptionally stressful few months.

Eventually, in the summer of 2009 David Cochrane arranged for payment of the redundancy
amounts, the fine and the court and solicitors’ fees, together with some outstanding costs of
the Consulting Association (NI contributions, accountant fees and telephone bills etc).
However, the payment was literally only to the very last penny and it was made only once
the ICO Crown Court proceedings had finished. The amounts were not paid to Ian direct, as
David Cochrane did not want the payments to be seen as Sir Robert McAlpine paying the
fine and, in the end they were paid to one of my daughters, who then transferred the money
to me.

In June 2011, David Cochrane also arranged for a further payment of Ian’s legal fees which
he had subsequently incurred with the law firm Wright Hassell in connection with two
Employment Tribunal claims against him and Balfour Beatty/Carillion by John Adair and
Edward Allen. The payment was only made following Ian’s letter of 13 June 2011 enclosing
documents relating to Cullum McAlpine’s involvement in the Consulting Association (such
as Ian’s original contract of employment and correspondence between Cullum and Ian
regarding pay rates, cars and health insurance).

All of the documents provided by Ian to David Cochrane in his June 2011 handwritten letter
had been personal to Ian and had been kept at home. Ian did not tell David Cochrane that
he had retained copies of the information and Ian told me that David Cochrane was clearly
very annoyed when he later told him (I think in about late 2011) that Ian had retained copies
of the documents.

Although David Cochrane was keen to keep Cullum McAlpine’s name out of things and paid
Ian’s fine and legal fees to obtain documents showing Mr McAlpine’s involvement, there was
not a significant volume of such documents because Mr McAlpine was not involved in the
day to day operation of the Consulting Association other than in approving salaries etc and
even this was really because it suited Ian personally to have the continuity of the same
person dealing with such matters.

David Cochrane was also unhappy when he later discovered that Ian was talking to GCR
and that Ian had handed over documents to GCR. David Cochrane asked Ian how he could
call himself a Christian. However Ian did not volunteer any documents to GCR; he only
provided documents because Sean Curran of GCR had forced Ian to do so, by threatening
to join Ian as a defendant to GCR’s group action. Ian only agreed to hand over his
documents in return for GCR not including him as a defendant in the proceedings, because
we could not have afforded the legal fees to defend the litigation and GCR knew this. Ian
was, in effect, forced to co-operate and Sean Curran knew that Ian had no choice but to
agree to hand over everything.

Sean Curran then relied on this when I asked for the documents back in late December
2012, shortly after Ian had died, but Sean refused to provide any of the documents to me
until he had discussed my request with his team. Sean Curran continued to stall in
answering my almost daily phone requests about the return of the documents until it was too
late and they had been handed over in the litigation in mid-January 2013. I felt that both Ian
and I had been used by GCR.

The last conversation between Ian and David Cochrane took place shortly after Ian had
provided his documents to GCR. The conversation was to our landline which was set to
hands free so I could hear what was said. I recall David Cochrane became angry about the
fact that Ian was “co-operating” with GCR. However, the documents Ian had been forced to
hand over were mostly personal documents, not Consulting Association documents. David
Cochrane reminded Ian of the financial payments he had received from Sir Robert McAlpine
and David Cochrane’s last words to Ian were that he would see Ian ‘in court’.

I am no friend of David Cochrane and I feel that he and the other member companies and
Main Contacts treated my husband appallingly in not supporting him in 2009 and in
pressurising him to avoid mentioning as far as possible any of the companies. However,
although I felt that David Cochrane placed pressure on Ian throughout to keep the
companies’ names and Cullum McAlpine’s name out of the limelight as much as possible
and he, along with the companies, were always willing for Ian to take the rap himself, David
Cochrane never asked Ian to lie in court. As a devout Christian, Ian would never lie —
whether under oath in court or in his personal life – and I think David knew this. Ian’s view to
the children had always been that telling lies was “lying to God”.

I still feel bitterness towards the companies because they each failed to stand by Ian
following the ICO raid and many individuals refused even to take Ian’s call. In addition, only
two individuals from the member companies ever sent a message on hearing of Ian’s death
in 2012.

10. Document Destruction

I am aware that there have been a lot of suggestions in the press and in these proceedings
about documents being destroyed. This was also brought up in the BBC Radio 4
programme ‘ The Report’ in February 2013.

I have mentioned above what sort of documents were kept at the Droitwich office and which
Ian kept at home. Mostly there were financial records, bills, old press-cuttings and general
information files. Obviously the key documents were the record cards themselves and the
Usage Figure files that recorded the number of names that had been checked and the
number of names that were picked up.

I understood from Ian that the ICO took away everything in the Droitwich office that they
wanted, including the record cards. However, this did not include the cash books and
personal correspondence, such as the documents relating to Ian’s and others’ salaries,
which we kept at home. There were also the back-up paper copy record cards which Ian
kept at home.

Ian’s written evidence to the Scottish Affairs Committee also confirms the position on this
issue, where he set out what was left behind. The words: The 90-95% of what was left
behind consisted of:.. ” refers to the contents of what was left behind as listed in his
written evidence; it does not mean that the ICO only took 5-10% of the record cards. The
90-95% of what was left was what he listed, which is the sort of generic documents (public
domain union, construction company and construction project information), admin
documents (historic minutes, running costs, copy invoices), original and copy press-
clippings and irrelevant financial documentation (VAT returns) that I have already described
above.

The documents left behind were not destroyed immediately following the ICO raid and, so
far as I am aware, Ian did not instruct the Consulting Association members to destroy their
own documents as a result of the ICO raid (he certainly never mentioned anything to me
about him or the members deciding to destroy documents). After the 2 March meeting with
the ICO, and once it was clear that the Consulting Association was to come to an end
permanently, Ian, Charlotte and I cleared the office, as Ian was anxious to avoid paying any
unnecessary rent. All invoice and general files, together with the computer, the fax
machine, the photocopier and the office furniture were taken by van to Ian’s sisters house
while we put in rubbish bags all the old press-cuttings and old magazines and newspapers.
The office furniture was later taken to the British Heart Foundation. From helping Ian clear
the office, I can confirm that there were no documents relating to any individuals left behind
by the ICO and no such documents were destroyed by Ian that the ICO did not already hold,
other than the green and pink record cards that were not taken by ICO because, as already
mentioned, they were in the (unlocked at the time) safe.

In addition, the Consulting Association computer was not destroyed. It was later given by
me to Phil Chamberlain who came to the house for the purpose of writing his book
“Blacklisted’ and I understand that he subsequently gave it away.

Ian destroyed all the Consulting Association documents retrieved from the office later in
2009, but only after the Crown Court hearing had finished. Ian had been told by the ICO
and the Court that the database was illegal and he did not want anyone to accuse him of
continuing with the operation illegally. He considered that it was, therefore, the best course
to destroy the remaining documents, even though they did not relate to individuals. There
was no intention on his part to destroy the documents to stop them being used as evidence
in any later litigation. In fact, it did not cross our minds that there would be any litigation, let
alone in the High Court.

In the Radio 4 documentary it was said by me that destroying the documents took Ian a full
three days to burn the remaining paper records. This is misleading; Ian probably spent an
hour or two each day over a period of several days. Trying to burn thick magazines,
newspapers, cardboard boxes and tough files is not such a quick job, particularly when it’s
wet and the fire was just left to smoulder over those days. There were never volumes and
volumes of correspondence or faxes with individual Main Contacts; that was just not how
the operation worked.

Generally, Ian would send mail-outs, meeting invitations, invoices and minutes etc by post
to member companies. He occasionally used the fax and we obviously received a lot of
faxes from the member companies, which we routinely destroyed on a daily basis after
2004.

Ian sent a very few emails to David Cochrane after the ICO raid using the email address
maryb602ab@fsmail.net. Ian did not have an email address himself and he generally did
not use a computer. He would write out or dictate what he wanted to say and I would send
the email; hence, my email address. If he wanted to look at something on the internet, Lucy
or I would locate the page and leave Ian to read it, but he frequently lost the page. Reading
was one of Ian’s passions and he had a very wide general knowledge – but it came from
reading books, not from surfing websites.

Statement of Truth
I believe that the facts stated in this witness statement are true.
Mary Kerr
21 January 2016

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