any event assist in establishing the specific facts surrounding the Complaints, I have made no finding about it and have not otherwise referred to it.
(4) Specificity
86. The DPM's written representations made a further point about the level of detail in the Complaints and in the summaries provided to him, contending that many of the matters included were "surprisingly non-specific". He argued that if I were to make factual findings based on non-specific allegations, there would be a risk of unfairness because there would not have been a sufficient opportunity to respond.
87. Where information such as dates and subject-matter of meetings was available, it was provided to the DPM. However, it is fair to acknowledge that some of the allegations made in the Complaints, together with the additional material obtained in the investigation, were based on what was said to have been an accumulation of experience but without specific details such as dates or particular meetings at which conduct is alleged to have occurred.
88. I have taken into account, in relation to the findings I have made, the legitimate difficulty for the DPM in dealing with allegations which were not specific. I should say that, in view of the nature of the allegations, I did not find such a lack of specificity to be particularly surprising. Nor did I regard it as a matter which by itself undermined the merit of any of the Complaints. In relation to those individuals working in private office, they would have had frequent contact with the DPM and often on numerous occasions every day. It was inherently difficult to remember any particular occasion. Unless a person had been keeping a contemporaneous record of events, it was unlikely that they would be able to remember specific details of dates and subject-matter. Meetings with policy officials tended to be less frequent and more focused on a particular subject-matter and so afforded a greater opportunity for specific recollection. Indeed, this was an obvious pattern in terms of the level of detail available in respect of the allegations made: allegations by policy officials tended to have a significantly higher level of specificity. Both specific and non-specific allegations were included within the Terms of Reference. If and to the extent that the allegations were put to the DPM in general terms, I was of course prepared to receive the DPM's response in similar terms and to make findings on that basis.
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