Dominic Cummings’ 10-page witness statement was submitted to the high court as part of the Cabinet Office defence of a judicial review of the contract awarded to Public First. Below are verbatim excerpts, edited to distil his explanation of his role in the process. It begins with the opening line of the section titled “Prior knowledge of Public First”. I am friends with James Frayne, Rachel Wolf and Gabriel Milland [partners at Public First]. I have not met James Frayne since 2016. I have previously worked with them in government and outside. For example, both James Frayne and Gabriel Milland worked at the Department for Education (“DfE”) when I was special adviser at DfE (2011-2015). James Frayne and I worked on the euro campaign 20 years ago, other political issues, and set up the campaign to fight the proposed formation of a regional assembly in north-east England in 2004. I have talked to them extensively about focus groups and public opinion over many years.
I knew from my experience that Public First were very good at running focus groups and that its key staff had thought extensively about how people who usually ignore most news and political communication think and might be influenced. I knew that I could rely on them to make an extra effort, beyond what they were paid to do. I knew they would give us honest information unlike many companies in this sector. Very few companies in this field are competent, almost none are very competent, honest and reliable. The Covid project contract The public health crisis developed quickly in February 2020. As the seriousness of the situation escalated, it became clear to me that, while there were very many brilliant officials who made enormous efforts throughout this crisis, Public Health England did not have the right resources in place to meet the government’s communications requirements of the emerging pandemic. […] They did not have the people or skills needed to undertake this type of public communications at speed. Neither did the DHSC [Department of Health and Social Care], the NHS or the Cabinet Office. Some of the first drafts of mass communication material were confusing and confusion clearly could have deadly consequences. So I became involved and started giving directions. […] Urgent help was needed to communicate effectively essential health messages to the public. I requested that Public First be brought in to mirror the focus groups already being done just as I also requested that the government start doing other polling in parallel to what it was already doing. I was the driving decision-maker on this. […] The country was facing an unprecedented national emergency. Thousands of lives were at stake, hundreds of billions of pounds were at stake. The extra money spent on doubling the focus groups and polling was essentially irrelevant in those circumstances. A few people did raise the question of how we could justify this as value for money. I responded that this was not the normal world, we were in a once-a-century pandemic and many thousands of pounds here was trivial if it helped us save lives and minimise economic destruction. It is important to stress that this exercise was totally non-political: I did not seek, nor was I interested in, anything to do with what other political parties were doing or saying – this exercise was only about the public health aspects of Covid. […] I am a special adviser and as such I am not allowed to direct civil servants. However, as a result of my suggestion, I expected people to hire Public First. The nature of my role is that sometimes people take what I say as an instruction and that is a reasonable inference as people assume I am often speaking for the prime minister. Civil servants could have disagreed and did disagree with my suggestions all the time and my response depends on my expertise of the matter in hand and other circumstances. On this occasion, I was an expert, I had just assembled a team of people to work on mass communication a few weeks earlier in the election campaign, I knew what the basic pillars of organising a communication campaign are and I expected people to listen to me. I had no involvement in the contractual arrangements with Public First or their remuneration. Urgency and allegations of apparent bias Obviously I did not request Public First be brought in because they were my friends. I would never do such a thing. […] The fact that I knew the key Public First people well was a bonus, not a problem, as in such a high-pressure environment trust is very important, as well as technical competence. […] I am sure that the work done by Public First allowed better and faster decisions and this saved lives and minimised damage. I would do the same again without a moment’s hesitation and I believe all those involved in mass communication would share this judgment. The full unedited witness statement is available here.