Module 7
- 30 May 2025
- 29 May 2025
- 28 May 2025
- 27 May 2025
- 22 May 2025
- 21 May 2025
- 20 May 2025
- 19 May 2025
- 15 May 2025
- 14 May 2025
- 13 May 2025
- 12 May 2025
- Opening Remarks by the Chair
- Opening Statement by Lead Counsel to the Inquiry for Module 7
- Submissions on Behalf of Covid-19 Bereaved Families for Justice by Mr Weatherby KC
- Submissions on Behalf of Northern Ireland Covid Bereaved Families for Justice by Mr Wilcock KC
- Submissions on Behalf of the Scottish Covid Bereaved by Dr Mitchell KC
- Submissions on Behalf of Covid-19 Bereaved Families for Justice Cymru by Ms Parsons
- Submissions on Behalf of the Federation of Ethnic Minority Healthcare Organisations by Professor Thomas KC
- Submissions on Behalf of the Trades Union Congress by Mr Jacobs
- Submissions on Behalf of the Local Government Association and the Welsh Local Government Association by Ms Stober
- Submissions on Behalf of the Cabinet Office by Mr Strachan KC
- Submissions on Behalf of the Department of Health In Northern Ireland by Ms Murnaghan KC
- Submissions on Behalf of the Scottish Ministers by Ms Drysdale KC
- Submissions on Behalf of the Welsh Government by Mr Kinnier KC
- Professor Naomi Fulop
- Ms Anna-Louise Marsh-Rees
- Transcript of Module 7 Second Preliminary Hearing, on 06 February 2025
- Statement by Lead Counsel to the Inquiry for Module 7
- Submissions on Behalf of Covid-19 Bereaved Families for Justice UK by Ms Munroe KC
- Submissions on Behalf of Northern Ireland Covid-19 Bereaved Families for Justice by Mr Nugent
- Submissions on Behalf of the Covid-19 Bereaved Families for Justice Cymru by Mr Stanton
- Submissions on Behalf of Scottish Covid Bereaved by Dr Mitchell KC
- Submissions on Behalf of the Federation of Ethnic Minority Healthcare Organisations by Mr Dayle
- 27 June 2024
- Statement by Senior Counsel to the Inquiry
- Submissions on Behalf of the Scottish Covid Bereaved Encourage the Inquiry to Consider Using A Neutral Term Which Defines the Issue Without Adopting the Approach In One Nation to Be the Norm With Other Nations Expected to Adapt to the Situation In England. Covid Bereaved Families for Justice Cymru Also In Their Submissions on Scope Highlight the Importance of the Significant Differences In the Test, Trace and Protect Policies Employed In Wales, With Numerous and Substantial Variance In Approach, Resources and Deployment Across the Home Nations Throughout the Relevant Period. My Lady May Consider That the Chair’s Provisional Outline of Scope Provides An Overarching Framework for the Issues and Matters That the Inquiry Is Likely to Investigate, to Enable Core Participants and Individuals and Organisations Likely to Have Relevant Evidence to Commence Their Preparations. My Lady May Also Consider That the Alternative Wording Is Not Required At This Stage, and the Wording Is Intended to Be Neutral. I Reiterate That Module 7’s Scope Remains Provisional, and If the Investigation and/or Further Evidence Reveals A Difficulty With Wording, Then We Consider That You, My Lady, As the Chair, Can Reflect and Change This If Aircraft. Turning Next to Submissions That Have Been Received In Respect of Module 7’s Title. Covid Bereaved Families for Justice UK and Northern Ireland Covid Bereaved Families for Justice In Their Joint Submission Have Invited the Inquiry to Add “support” to the Title of Module 7. They Submit That the Provision of Support, Economic and Otherwise, for Those Who Tested Positive Was A Crucial Component for An Effective Test, Trace and Isolation Response to the Pandemic. Module 7 Will Consider Factors Influencing Compliance With Test, Trace and Isolate Rules, Which Will Include Consideration of the Financial and Practical Support to Those Required to Isolate, As Set Out At Point 4 of the Provisional Outline of Scope. We Are Grateful for the Suggestion and My Lady May Consider That the Current Module Name and References to Support In the Provisional Scope Is Sufficient. My Lady, I Next Turn to Summarise Further Submissions That Have Been Received on the Scope of Module 7. the Following Points on Scope Were Raised and I Draw Your Attention to Today and Provide An Initial Response on Behalf of Module 7. We Are Grateful for the Submissions of the Tuc Which Detail That the Provisional Outline of Scope Is Sufficiently Broad and Do Not Invite Amendment But They Request Two Points of Clarification As to the Interpretation of “vulnerable” and Also Ask If the Adult Social Care Infection Prevention and Control Fund Will Be Considered In Module 7. This Module Will Seek Evidence From Relevant Material Providers on Financial Support As It Relates to Or Could Have Influenced Compliance With Test, Trace and Isolate Policies and Rules. I Mentioned Earlier That A Future Module Is Likely to Review the Government’s Business and Financial Responses and Module 6 Is Also Looking At Social Care. Close Co-ordination Will Continue With Those Modules on Financial Support Available, Including In Respect of the Adult Social Care Infection Prevention and Control Fund Specifically. Further, This Module Is Not Limited to Seeking Evidence In Relation to Vulnerability But Will Seek to Explore Issues and Request Evidence Relevant to Test, Trace and Isolate From A Range of Different Groups and Populations With Varying Characteristics, Such As, and Not Limited to, Key Workers, In Crowded Housing, Those From Ethnic Minority Backgrounds, Those With Pre-existing Health Conditions, and Those From Low Incomes. Covid Bereaved Families for Justice Cymru and Femho Have Provided A List of Issues of Particular Importance to Them and for the Consideration of the Inquiry. My Lady May Consider That the Issues Helpfully Set Out Can Be Summarised Into the Following Categories: Decision-making of the Welsh Government With Regards to Testing, Tracing and Isolation Policies and Strategies, and How This Differed; Accessibility and Availability of Testing; Delays to Testing; and Public Communication. These Are Topics Which Will Be Scrutinised by the Inquiry and We Encourage Covid Bereaved Families for Justice Cymru and Others Who Wish to Provide Relevant Evidence to Do So. We Reiterate Our Commitment to Covid Bereaved Families for Justice Cymru That They Will Be Issued With Requests for Evidence, and Similarly, My Lady, In Respect of Femho A Request Has Already Been Issued to Femho. Covid Bereaved Families for Justice UK and Northern Ireland Covid Bereaved Families for Justice In Their Joint Submission Recognise the Wide Scope of Module 7 But Express Concerns As to What They Describe As “notable Omissions”, With the Scope Referring Almost Exclusively to the Period of Response From 1 January 2020 Which They Submit “neglects to Include the Crucial Issue of Preparedness.” Their Submission Encourages the Inquiry to Consider the Position As At 1 January 2020 Preparedness and the Position From 1 January 2020 the Response. Module 1 Has Considered Preparedness and This Module Will Consider the Capacity for Testing and the Expansion of It From January 2020. In Considering the Capacity Already Available to Key Decision-makers At the Time Across the Devolved Administrations, Resources Prior to the Pandemic and Preparedness Will Be Looked At. My Lady May Consider the Combination of These Does Not, With Respect, Give Rise to A Notable Omission and That It Is A Proportionate Approach In This Module. Further, Covid Bereaved Families for Justice UK and Northern Ireland Covid Bereaved Families for Justice Observe There Is Little Mention In the Provisional Scope In Relation to Discrimination, Inequalities and Disparity of Outcomes, With the Only Reference Being to the Public Sector Equality Duty. the Submission of Covid Bereaved Families for Justice United Kingdom and Northern Ireland Covid Bereaved Families for Justice Is That Issues of Structural and Institutional Race Discrimination and Other Forms of Discrimination, Particularly Disability, Are As Important In This Module As In Other Parts of the Inquiry, and They Urge the Inquiry to Amend the Scope to Reflect This. My Lady, You Have Stated In Your Commitment In Meeting the Aims of the UK Covid-19 Inquiry to Investigate the Unequal Impact of the Pandemic on Different Categories of People Across the United Kingdom, Including But Not Limited to Those With Protected Characteristics Under the Equality Act 2010 and Equality Categories Under the Northern Ireland Act 1998. My Lady, You Have Been Absolutely Clear That the Vital Issue of the Impact of the Pandemic and the Response to It on At-risk Or Vulnerable Or Marginalised People, and on Ethnic Minority Groups, Has Been At the Heart of This Inquiry Since Its Inception. Module 7 Is Actively Seeking Evidence to Give Particular Consideration to Groups With Protected Characteristics, Geographical Differences, Social Economic Background, Occupation and Immigration Status. Module 7’s Investigation Includes Seeking Evidence to Understand Any Unequal Impact. the Inquiry Will Do So by Asking Core Decision-makers Along With Bespoke Questions, That Which Is Outlined In the Inquiry’s Equalities and Human Rights Statement: Did Decision-makers Consider the Impact of Policy Decisions on Each of These Groups? and Were the Decisions Taken As A Result Adequate In Mitigating the Impact of the Pandemic on These Groups? My Lady, Moving Next to Evidence Requests and Rule 9 Update. the Inquiry Has Already Either Issued Or Is About to Issue Formal Requests for Evidence, Pursuant to Rule 9 of the Inquiry Rules 2006 to A Number of Individuals and Organisations Which Appear to Have Played A Central Or Significant Role In Matters Relevant to Module 7. These Include, by Way of Headline: Government Departments of the United Kingdom and Devolved Administrations, Including the Department of Health and Social Care, His Majesty’s Treasury, Department for Education, the Home Office, the Ministry of Justice, the Department for Levelling Up, Housing and Communities; the Department for Culture, Media and Sport; the Cabinet Office; Department for Transport; Department of Health and Social Services Wales; Health and Social Care Directorate Scotland; Department of Health Northern Ireland. In Addition, Committee Decision-makers In the United Kingdom Government and the Devolved Governments In Wales, Scotland and Northern Ireland Will Be Receiving Rule 9 Requests Regarding Test, Trace and Isolate. Executive Agencies and Non-departmental Public Bodies, Including the UK Health Security Agency, Sage, Spi-m-o, the Scientific Pandemic Influenza Group on Modelling, Operational, the Joint Biosecurity Centre; Medicines and Healthcare Products Regulatory Agency; Nhs England and Nhs Digital; Nhs National Services Scotland; Health Protection Scotland; Public Health Agency, Northern Ireland; the Local Government Association and Welsh Local Government Association; Northern Ireland Local Government Association; the Convention of Scottish Local Authorities; the Association of Directors of Public Health; Criminal Justice and Enforcement Agencies. Further Relevant Key Individuals, Including Baroness Dido Harding, Sir Patrick Vallance, Professor Chris Whitty and Professor Sir Jonathan Van-tam, Relevant Organisations Such As the Royal Statistical Society, the Microbiology Society and Professional Individuals With Specialist Knowledge and Expertise Relevant Relative to Test, Trace and Isolate. Groups and Organisations Representing Specific Areas of Interest Within the Scope of Module 7, Including the Covid Bereaved Family Groups, Clinically Vulnerable Families, Disability Action Northern Ireland, Disability Rights UK, Long Covid Groups, Femho, the Traveller Movement, Trade Unions and Representative Bodies for Health and Social Care Professionals, and Those Representing Minority Or Marginalised Communities and Individuals. Finally, Private Suppliers, Which I Will Address Separately Later. As My Lady Is Aware, This Inquiry and the Scottish Covid-19 Inquiry Are Keen to Avoid Duplication Between Them and So the Module 7 Team Is Checking Not Only the Requests Made by Other Inquiry Modules But Also Those Made by the Scottish Inquiry. That Process Means, Inevitably That It Takes A Little More Time to Issue Rule 9 Requests to Scottish Bodies, But It Is Hoped That In the Long Run This Approach Will Assist In Minimising Unnecessary Repetition. In That Regard, I Should Add That, on 23 February 2023, the Inquiry Published A Memorandum of Understanding Setting Out How This Inquiry and the Scottish Covid-19 Inquiry Intend to Work Effectively Together. I Am Also Aware That Your Ladyship Has Met With the Chair of the Scottish Inquiry, Lord Brailsford, to Discuss the Constructive Ways In Which the Two Inquiries Can Collaborate and Co-operate. the Inquiry Is Grateful for All the Suggestions Made In the Written Submissions As to Who Should Receive A Rule 9 Request From the Trades Union Congress and the Inquiry Legal Team Has Already Started to Consider Those Proposals. As the Rule 9 Requests Will Be Issued on A Rolling Basis to Organisations and Witnesses, Some Issues Will Come Into Greater Focus, No Doubt, During the Course of the Investigation. Femho In Their Submissions Reiterates Its Position In Previous Modules and Asks You, My Lady, to Reconsider Your Position on Disclosure of Rule 9 Requests to Core Participants. In Line With Your Determination Made In Module 1, Core Participants Will Not Be Provided With Copies of the Rule 9 Requests Made by the Inquiry. Disclosure to the Core Participants of the Rule 9 Requests Themselves, As Opposed to the Documents and the Material Generated by Those Requests, Is Neither Required by the Rules Nor Generally Established by Past Practice. Furthermore, In Our Submission, It Would Serve Little Practical Purpose, Given the Wide Scope and the Detailed Nature of Rule 9 Requests That Are Being Made. to Ensure, Though, That the Core Participants Are Properly Informed the Inquiry Will Ensure That the Module 7 Lead Solicitor Provides Monthly Updates to Core Participants on the Progress of Rule 9 Work, and Those Updates Will Include A Summary of Who of Has Received Rule 9 Requests and the Expected Response Dates. My Lady, Turning Next to Say A Few Things About Private Companies and Organisations. Your Ladyship Is Aware That When the Draft Scope of Module 7 Was Circulated In Advance of Invitations for Applications for Core Participant Status, You Indicated That You Were Particularly Interested In Receiving Core Participant Applicants From Those Individuals Or Bodies Who Made Key Decisions In the Test, Trace and Isolate System, Rather Than Seeking Applications From the Large Volume of Suppliers Contracted to Provide Test, Trace and Isolate Services Or Equipment In the Pandemic. You Also Indicated That Some Suppliers May Be Able to Contribute to the Inquiry by Providing Evidence About Their Experience, But That They Did Not Need to Be A Core Participant to Do That. the Module 7 Team Is Aware That Hundreds of Private Companies and Organisations Were Involved In Testing, Tracing and Implementation of Quarantine and Isolation Rules, Along With Independent Private Consultants Across the System. the Module 7 Scope Has Been Purposely Drafted So As to Focus on the Core Decision-making of the UK and Devolved Nations, Rather Than the Actions of the Private Sector Companies Involved. However, Module 7 Will Invite Evidence on Your Behalf From Selected Supplier Companies and Organisations by Issuing Rule 9 Requests, Asking Each to Explain Their Role In the Test, Trace and Isolate System and to Ensure That the Experience and/or Learning That They Might Speak to Can Be Considered. Broadly Speaking, Commercial Organisations Were Contracted to Conduct the Following: Project Management and Support Services; Managing and Operating Testing Sites, and Providing Laboratory Capacity and Processing for Pillar 2 Testing; Provision of Test Kits and Supplies; Providing National Contact Tracing; Developing and Providing Digital Services for Test and Trace, As Well As Developing A Contact Tracing App. the Work Has Already Begun With Organisations Having Been Identified Who Have Evidence Directly Relevant to Module 7 Issues In A Substantive Way. Rule 9 Requests Have Been Drafted Or Are In the Process of Being Drafted, Including and Not Limited to: Deloitte; Medicines Discovery Catapult; the Lighthouse Laboratories Operated At Cambridge, Milton Keynes, Cheshire, Glasgow, Loughborough, Newport, Berkshire, Gateshead, Plymouth and Leamington Spa; Accenture; Ibm UK; McKinsey & Co UK; Zuhlke Engineering; Randox; Sitel; Sodexo; and Roche. My Lady, Turning Next to the Issue of Expert Evidence. Module 7 Is In the Process of Identifying the Broad Areas Where Expert Evidence Is Likely to Be of Assistance to This Module of the Inquiry. My Lady May Consider It Likely That Expert Evidence on the Range of Testing Technologies and Strategies, As Well As the Issues Surrounding Uptake, Access and Compliance With These Policies and Strategies, Will Be Sought. It Is Highly Likely That Any Expert Instructed Will Have Reasonable Regard to Relevant International Comparison, Which Is An Issue Raised by Core Participants In Their Submissions. the Inquiry Is Currently Approaching Experts Who Are Being Considered for Instructions. A Number of Core Participants In Their Submissions Have Made Suggestions About Area of Potential Expert Evidence for Module 7 and These Will Be Given Careful Consideration. the Submissions of Scottish Covid Bereaved Seek to Encourage the Instruction of Experts With Sufficient Expertise Concerning Scotland and the Scottish Government’s Policies and Practices. the Submissions of the Tuc Request Expert Evidence to Examine International Comparative Data and to Explore Trends Globally During the Pandemic to Assist Assessment of the Efficacy of the Schemes Implemented In the United Kingdom and In Making Evidence-based Recommendations for A Future Pandemic. Covid Bereaved Families for Justice UK and Northern Ireland Also Make Submissions for Expert Evidence In Respect of Comparative International Public Health Systems by Way of “proportionate Evidence” Identifying A Small Number of Other Countries Where the Approach Taken to Test, Trace and Isolate Appears to Have Been Instrumental In Achieving Better Outcomes. Covid Bereaved Families for Justice United Kingdom and Northern Ireland Also Request Expert Evidence on the Issue of Discrimination and Structural and Institutional Race Discrimination and Other Forms of Discrimination, Particularly Disability, As Being Crucial to Understanding the Full Impact of the Test, Trace and Isolate Strategies on Diverse Communities and Workforce. the Covid Bereaved Families for Justice United Kingdom and Northern Ireland Encourage Investigation As to Whether the Experts Commissioned to Report on Other Aspects of Discrimination and Inequalities In Other Modules May Have Knowledge and Evidence to Provide Additional Expert Evidence Relating to Test, Trace and Isolate Or to Assist With Identifying Others More Suitable to Do So. Femho Also Makes Submissions That Expert Evidence Should Be Obtained From A Specialist In Race Inequality, Potentially In the Form of Follow-up Reports by the Experts Instructed for Module 2 to Provide Detailed Opinion on the Inequality Issues Relating to Test, Trace and Isolate. the Covid Bereaved Families for Justice United Kingdom and Northern Ireland Seek Consultation With Them on the Identification of Appropriate Experts and A Timeline for When Draft Reports Will Be Disclosed. My Lady, You and Many of the Core Participants Involved In Previous Modules Will Be Aware That the Inquiry to Date Has Instructed Numerous Experts Across Different Disciplines. the Approach Has Been to Instruct Experts Who Have the Requisite Expertise to Be Able to Comment, Where Appropriate, on Devolved Administrations, Make International Comparisons and Equalities. the Core Participants’ Submissions on the Appropriateness and Expertise Required for Experts Are Noted and Are Matters That the Module 7 Team Will Carefully Consider Prior to the Instruction of the Experts. the Identities of Instructed Experts Will Be Contained In the Solicitor to the Inquiry’s Update Notes. Once Experts Are Instructed, These Notes Will Also Provide Further Details of the Topics Which the Experts Will Address In Their Reports, Thereby Enabling Core Participants to Comment on Those Matters Should They Wish to Do So. In Addition to This, As In Other Modules, Core Participant Organisations Will Have the Opportunity to Comment Substantively on the Content of A Draft Version of the Reports. My Lady, Turning Next to Disclosure. In Common With the Approach Taken In Previous Modules, Module 7 Will Adopt the Following Approach to Disclosure. All Core Participants Will Receive All Documents Disclosed In Module 7, Not Just Those Documents Relevant to Them. Disclosure Will Be Subject to Three Things: First, A Relevance Review So That Only Relevant Documents Are Disclosed; Second, A De-duplication Exercise; Third, Redactions In Accordance With the Inquiry’s Redaction Protocol. A Team of Solicitors, Barristers and Paralegals Is Already In Place to Review the Relevant Disclosure That Has Been Received In Previous Modules and They Will Review This for Relevant Disclosure In Module 7 As They Also Will Consider Disclosure As Received In Respect of Module 7. Disclosure Is Likely to Be In Tranches Made on A Rolling Basis. Disclosure Will Be Made Via the Electronic Data Management and Disclosure System Relativity, and Again Disclosure Updates Will Be Provided by the Module 7 Solicitors Team, Informing Core Participants of the Progress Which Has Been Made In Obtaining Relevant Documents. We Will, of Course, Also Provide These At the Next Preliminary Hearing. the Inquiry, As I Have Already Indicated, Has Begun Work by Reviewing Documents Received by Modules 1 to 8 to Date That Have Been Identified As Having Potential Relevance to Module 7 Issues. A Review of Those Documents, Including Expert Reports, Will Be Conducted and Relevant Documents Disclosed to Core Participants As Soon As Possible. This Is A Matter A Number of Core Participants Raise In Their Submissions, Namely the Issue of Timely Disclosure to Ensure Effective Preparation. the Process of Disclosure to Core Participants Is Anticipated to Begin In Autumn 2024. Covid Bereaved Families for Justice Cymru and the Scottish Covid Bereaved and Covid Bereaved Families for Justice United Kingdom and Northern Ireland All Request Timely Disclosure to Allow Proper Preparation for the Substantive Hearing. Covid Bereaved Families for Justice UK and Northern Ireland Suggest A Date At Least Two Months Before the Start of the Hearings for the Bulk of Disclosure. We Are Grateful to the Tuc for Identification of A Helpful List of Documents Suggestive of Cross-disclosure In Module 7. Covid Bereaved Families for Justice UK and Northern Ireland Also Submit That Each Document Provider Should Provide A Corporate Narrative to Address What Did and Did Not Happen With Respect to the Issues of Module 7, and Who Was Or Should Have Been Responsible for That, Viewed Through Their Own Institutional Knowledge and Perspective. Each Document Provider Is Being Asked to Provide, Amongst Other Matters, Details of the Key Individuals Who Are Involved In Issues Relevant to Module 7’s Provisional Outline of Scope, the Key Meetings and A Summary of the Categories of Other Material Held and/or Already Provided to the Inquiry Relating to the Module 7 Provisional Outline of Scope. This Information Will Allow the Inquiry to Understand the Nature of Relevant Material Held by the Document Provider and to Make Targeted Requests for Further Material If Necessary. Where, As A Result of the Information Provided, the Inquiry Has Any Concerns About A Provider’s Processes for Providing Relevant Documents, It Will Raise and Pursue Them and, of Course, As Documents Are Reviewed and Gaps Identified, Further Documents May Be Sought. of Course, My Lady, You Also Have the Power to Compel the Production of Documents Under Section 21 of the Inquiries Act and There Are Provisions In Section 35 of the Inquiries Act Which Is Make It An Offence, During the Course of An Inquiry, for A Person to Do Anything to Alter Or Distort A Relevant Document Or Prevent Any Relevant Document Being Produced to the Inquiry, Or to Intentionally Destroy, Suppress Or Conceal A Relevant. My Lady, Turning Next to Every Story Matters. Every Story Matters Is the Name Given to the Inquiry’s Nationwide Listening Exercise. My Lady, the Inquiry’s Terms of Reference Make Clear That Although the Inquiry Will Not Investigate Individual Cases of Harm Or Death In Detail, Listening to the Accounts and Experiences Experience of the Bereaved Families and Others Who Suffered Shard to Be Or Loss Will Inform the Inquiry’s Understanding of the Impact of the Pandemic and the Response and of the Lessons to Be Learnt. Every Story Matters Is Therefore the Process by Which the Public Can Contribute to the Inquiry, So That It Will Be Able Not Just to Hear the Voices of the People of the United Kingdom and to Reflect Upon Their Experience, But Also to Incorporate the Emerging Themes Into Its Work. Every Contribution Through Every Story Matters Will Be Analysed and Turned Into Themed Reports, Which Will Be Submitted Into Each Relevant Investigation. These Reports Will Be Anonymised, Disclosed to the Inquiry’s Core Participants and Used In Evidence. the Reports Will Identify Trends and Themes and Include Illustrative Case Studies Which May Demonstrate Systemic Failures. Every Story Matters Aims to Obtain Insights and Information From Anyone Who Wishes to Contribute; That Is, From Anyone Who Was Impacted by the Pandemic and Wishes to Share Their Experience. It Has Been Designed So That Anyone and Everyone In the United Kingdom Who Is Aged 18 Or Older Can Contribute If They Wish to Do So. There Are Different Ways for People to Share Their Experience of the Pandemic With the Inquiry. This Can Be Done Via Our Web Form, A Variety of Alternative Formats, Including Easy Read and Paper Forms, Or Through Community Listening Events Around the Country. We Are Grateful to the Covid Bereaved Families for Justice Cymru for Their Indication That Those Who They Represent Are Looking Forward to Engaging With Every Story Matters. Femho, As A Consortium Representing 55,000 Individual Members and 43 Organisations and Networks, Encourages Module 7 to Receive Testimonies From Ethnic Minority Healthcare Workers and Community Members to Provide A Nuanced Understanding of the Test, Trace and Isolate Strategies’ Impact and to Highlight Areas for Improvement. We Would Encourage and Invite Femho Members, In Light of This Submission, to Share Their Experiences Through Every Story Matters. for Module 7, the Inquiry Is Seeking to Capture A Broad Range of Experience and Is Particularly Interested to Hear From Those Who Are More Likely to Have Had Difficulties Engaging With the Test, Trace and Isolate System, Including Those Across the Devolved Nations, for A Variety of Reasons. This Could Include, But Is Not Limited to, Those With Literacy and Learning Difficulties, the Visually Impaired, and Those With Challenges Accessing Testing Sites and Health Services. These Experiences Will Be Analysed and Reviewed by the Inquiry’s Research Partner Based on Key Lines of Enquiry (kloes) for Every Story Matters, Produced by the Inquiry Team. the Key Lines of Enquiry Are An Important Tool for Setting Throughout Way In Which the Inquiry Will Gather and Analyse Experiences Shared With Every Story Matters, In Particular Through the Targeted Research. the Inquiry’s Research Partner and the Inquiry Legal Team Have Been Exploring the Opportunity to Conduct Targeted Qualitative Research In Relation to Particular Topics and Particular Groups of People Based on the Kloes. the Draft Kloes for Module 7 Targeted Research Were Circulated to Core Participants. for Module 7, Targeted Research Is Being Undertaken to Hear the Experience of Families of People Who Were Clinically Vulnerable During the Pandemic, Ethnic Minority Health and Social Care Workers, People Living With Long Covid, and People With Disabilities, Among Other Target Groups. the Inquiry’s Research Partner Will Conduct Targeted Qualitative Research In Relation to Particular Topics and Particular Groups of People Based on the Kloes. It Is Proposed In Module 7 That This Research Will Focus on, Among Other Things, Listening to People From Different Communities and Backgrounds Where There Were Particular Difficulties and the Impact Caused to Them by the Test, Trace and Isolate System. the Key Lines of Enquiry Will Be Published on the Website When Finalised. It Is Unlikely That the Targeted Research Will Be Able to Cover All the Areas Listed In the Draft Kloes. Core Participants Were Invited to File Written Submissions Making Suggestions In Relation to the Kloes for This Targeted Qualitative Research. Core Participants Have Provided A Number of Helpful Submissions In Respect of the Kloes and the Approach to Targeted Work, for Which We Are Grateful. These Submissions Will Be Reviewed In Detail by the Inquiry Team and Will Help Inform the Work on the Kloes. In the Coming Weeks, the Inquiry Legal Team Will Work With Its Research Partner to Finalise Potential Research Questions and Priority Audiences In Relation to the Proposed Kloes. It Is Right to Note That the Every Story Matters Listening Exercise, Including Its Targeted Research, Is But One Part of the Inquiry’s Broader Consideration of the Experience of Groups and Individuals Impacted by Matters Falling Within the Provisional Outline of Scope for Module 7. the Experiences of Many More Groups and Individuals From A Large Range of Different Communities and Backgrounds Will Be Collected by Means of the Accounts Offered to the Inquiry Through Its Rule 9 Investigatory Requests. Turning Next, My Lady, to Commemoration. My Lady, You Have Made Clear You Wish to Recognise the Very Real and Human Suffering Arising From the Pandemic by Ensuring That It Is Properly Considered and Reflected In the Inquiry’s Work. As You Know, the Inquiry Is Producing A Series of Impact Films, the First of Which Was Screened At the Modules’ Public Hearings In Module 1 and Module 2, 2A, B and C, and Has Used Images and Artwork to Try to Represent Elements of the Loss and Suffering Caused by the Pandemic to the People of the United Kingdom. Such Was the Scale of the Tragedy, the Grief and Loss Suffered by the Bereaved, and the Lasting Effect of the Pandemic on the Lives of So Many Millions of People, That No Amount of Commemorative Activity Could Ever Adequately Reflect the Depth of Suffering Experienced by So Many. However, the Inquiry Remains Committed to Listening to the Voices of Those Most Impacted by the Pandemic and to Continue to Deliver Commemorative Activity That Recognises the Scale of This Tragedy, and the Effect It Had – and Continues to Have – on People’s Lives. There Will Be A New Impact Film Played At the Start of Module 7. These Films Are A Powerful Means of Reminding Ourselves of the Impact of the Pandemic and, Although They Do Not Strictly Constitute Evidence, They Help to Ground Proceedings In the Lived Experience of Those Who Have Suffered Hardship and Loss. My Lady, Turning Next to Directions. As You Know, My Lady, the Current Plans Are That Module 7 Hearing Is Expected to Take Place Over Three Weeks In the Spring of 2025. Further Timetabling Details Will Be Provided by Way of An Update to Core Participants In Due Course. These Will Also Be Announced on the Inquiry’s Website, and the Hearing Will Be Held Here At Dorland House. It Is Right to Highlight That You Have Received Joint Submissions From Covid Bereaved Families for Justice UK and Northern Ireland That the Three-week Hearing Is An Inadequate Time Frame, Especially Considering That the UK and the Devolved Administrations Each Had Their Own Distinct Systems of Test, Trace and Isolate. In Light of the Evidence That Will Have Been Heard In Modules 1 to 5, the Provisional Scope of Module 7, the Intended Approach to Collation of Evidence by Rule 9 Requests, Module 7’s Intended Approach to Its Use of Experts, the Substantive Evidence Can Be Achieved In Three Weeks. It Is A Tight Timetable But, With A Focus on the Key Issues and the Co-operation of Core Participants, We Consider That the Hearing Timetable Can Be Maintained. My Lady, I Know That Once You Have Had An Opportunity to Consider the Written Submissions and Those That Are Being Made Orally Today, You Will Publish Any Necessary and Appropriate Directions In Due Course. Turning Then to Next Dates for Module 7, There Will Be A Further Preliminary Hearing for Module 7 and We Will Notify Core Participants When the Next Preliminary Hearing Is Due to Take Place and It Will Be Published on the Inquiry’s Website. This Is Currently Scheduled for Early 2025. My Lady, Moving Next to Submissions From Core Participants. My Lady, That Concludes All of the Matters Upon Which I Wish to Address You on Behalf of Counsel to the Inquiry. A Number of Core Participants Wish to Address You Orally During the Course of This Hearing, and So Can I Invite You to Hear From Those, Namely: Scottish Covid Bereaved; Covid-19 Bereaved Families for Justice Cymru; Covid Bereaved Families for Justice United Kingdom; Northern Ireland Covid Bereaved Families for Justice; the Federation of Ethnic Minority Healthcare Organisations; the Trades Union Congress; the Welsh Government. A Further Written Submission Was Received by the Department for Education Relating to the Draft Key Lines of Enquiries. I Am Grateful to Ms Ward King’s Counsel and to the Department for Education for Confirming That They Do Not Wish to Address You Orally In Respect of Their Short Written Submissions. My Lady, There Appears to Be Time Before the First Break for You to Hear the Submissions on Behalf of the Scottish Covid Bereaved, and, My Lady, With Your Approval Can I Turn First to Mr McCaffery to Make the Oral Submissions He Wishes to Make In Respect of the Scottish Covid Bereaved, and Mr McCaffery Attends Over the Link, My Lady.
- Submissions on Behalf of Scottish Covid Bereaved by Mr McCaffery
- Submissions on Behalf of Covid Bereaved Families for Justice Cymru by Ms Weereratne KC
- Submissions on Behalf of Covid-19 Bereaved Families for Justice UK by Ms Munroe KC
- Submissions on Behalf of Northern Ireland Covid Bereaved Families for Justice by Mr Bindman
- Submissions on Behalf of the Federation of Ethnic Minority Healthcare Organisations by Mr Thomas KC
- Submissions on Behalf of the Trades Union Congress by Ms Peacock
- Submissions on Behalf of the Welsh Government by Mr Rogers