Referring to the theft of credit card numbers, Mr Lambert, the Otto UK Group Security Manager, stated in paragraph 31 of his statement that

"It is quite probable that as paper is not allowed out of the call centre, staff are using mobile ‘phones to remove such numbers".

During cross-examination, I double-checked. I asked Mr Lambert whether there was any proof that anyone had ever used a mobile ‘phone to steal information. He answered, simply,

"No".

Incidentally, Grattan’s call centre was open plan, and there was a sign at the entrance warning employees not to have mobile ‘phones switched on.

Mr Lambert did say that paper is not allowed out of the call centre. During cross-examination, I reminded him that people often walked in and out of the call centre with computer printouts and other documents (I had often done so myself, as part of my job). There was even a shop in the call centre in which employees could buy newspapers, etc. Mr Lambert explained that it is the paper used by clerks to write down information that should not be removed from the call centre.