Mr. Cian O'Carroll:

Deputy Cullinane raised the issue of the cover-up as a first point. It is an emotive term but I think it is fair to say that, from the documentation, you can clearly see there was a co-ordinated and a premeditated plan to deny patients the information, although not in total. The documentation suggests that it was envisaged that some patients would be told of the audit, albeit quite late in the day. Nobody was to be told before the middle of 2016 and, at that point, people were to be selected. It is the criteria for their selection that causes a major problem for disclosure. We see from the documentation that doctors were told not only could they be selective with their patients, but if the woman had died, they were not to tell her family and it was simply to be put in the file. That appears in a number of documents and it turns up in the CervicalCheck preprinted leaflet that was sent out to the clinicians telling them how to deal with the audit in July 2016. More than 120 pages of documents were released yesterday by the Department of Health.

I have not considered them in detail, but I did notice that there is a set of precedent letters towards the back of that bundle which are to be used by CervicalCheck. Included in that bundle is a letter to clinicians. The letter includes a line about open disclosure but beside that, in the Microsoft Word format, is a comment which tells the person reading the precedent document that in cases where a woman has died this sentence is to be deleted from the letter and there is to be no reference to open disclosure. Therefore, we see that there is a thread moving through documents which suggests that there was a premeditated and orchestrated plan to keep this information from patients who had died in particular.

Furthermore, in the correspondence between CervicalCheck's Professor Flannelly and Vicky's consultant gynaecologist, there is a dialogue going on over a period of more than a year - 15 months - in which two clinicians are talking to one another and in which CervicalCheck's clinical director is saying that she does not believe that all these women should be told. At one point she describes three of the ten patients who were on that list as meeting her clinical criteria for being told, yet we know that all of those women had suffered some degree of delay in the treatment of their cancer. While I cannot comment in any meaningful way about the degree to which they were all affected by that delay, from the reports of this audit I have seen to date - and the records have been slow in coming through - four out of four women have been significantly affected. It is reasonable at least to say that doctors looking at those records must have known that there had been a very significant clinical effect on women.