Inspection on 20/10/05 for Angel Home

This inspection was carried out on 20th October 2005.

CSCI has not published a star rating for this report, though using similar criteria we estimate that the report is Adequate. The way we rate inspection reports is consistent for all houses, though please be aware that this may be different from an official CSCI judgement.

The inspector found there to be outstanding requirements from the previous inspection report. These are things the inspector asked to be changed, but found they had not done. The inspector also made 5 statutory requirements (actions the home must comply with) as a result of this inspection.

Other inspections for this house

Angel Home 12/06/07

Angel Home 21/06/06

Angel Home 25/05/05

Angel Home 07/01/05

Angel Home 04/11/04

Similar services:

Ashlong House

Norbury Crescent (30)

Edenvale

Wadham Avenue

Chatsworth Care - Dawson House

Cowden Road, 52 - 54

Chatsworth Care - Tudor Lodge

Foxley Lane (121a)

Extracts from inspection reports are licensed from CQC, this page was updated on 08/07/2008.

CARE HOME ADULTS 18-65 Angel Home Angel Home 43 Stayton Road Sutton Surrey SM1 1QY Lead Inspector Ms Rin Saimbi Unannounced Inspection 20th October 2005 02:30 Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 1 The Commission for Social Care Inspection aims to: • • • • Put the people who use social care first Improve services and stamp out bad practice Be an expert voice on social care Practise what we preach in our own organisation Reader Information Document Purpose Author Audience Further copies from Copyright Inspection Report CSCI General Public 0870 240 7535 (telephone order line) This report is copyright Commission for Social Care Inspection (CSCI) and may only be used in its entirety. Extracts may not be used or reproduced without the express permission of CSCI www.csci.org.uk Internet address Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 2 This is a report of an inspection to assess whether services are meeting the needs of people who use them. The legal basis for conducting inspections is the Care Standards Act 2000 and the relevant National Minimum Standards for this establishment are those for Care Homes for Adults 18-65. They can be found at www.dh.gov.uk or obtained from The Stationery Office (TSO) PO Box 29, St Crispins, Duke Street, Norwich, NR3 1GN. Tel: 0870 600 5522. Online ordering: www.tso.co.uk/bookshop This report is a public document. Extracts may not be used or reproduced without the prior permission of the Commission for Social Care Inspection. Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 3 SERVICE INFORMATION Name of service Angel Home Address Angel Home 43 Stayton Road Sutton Surrey SM1 1QY 020 8715 6940 020 8647 2548 Telephone number Fax number Email address Provider Web address Name of registered provider(s)/company (if applicable) Name of registered manager (if applicable) Type of registration No. of places registered (if applicable) Angel Home Limited Mrs Christine Mouralidarane Care Home 5 Category(ies) of Learning disability (5) registration, with number of places Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 4 SERVICE INFORMATION Conditions of registration: Date of last inspection 25th May 2005 Brief Description of the Service: Angel Home is a residential care home for five younger adults who have learning disabilities. The home itself is an end of terrace house situated on a residential road in Sutton. The accommodation compromises of a two storey building; on the first floor there is a lounge/diner, kitchen, toilet, small office, laundry room and one bedroom. There is access via the kitchen and lounge/dining room to a small garden, which is dominated by a ramp. On the second floor, there is a further four bedrooms and a bathroom. To the front of the building there is a small garden. There is restricted car parking near the home, although the home itself has parking for one vehicle at the back of the property. The home is within easy walking distance of Sutton town centre, where there are shops, post office and pubs. Sutton has good transport links as it is on many bus routes and there is also a railway station that goes into London and the coast. Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. This was Angel Homes second inspection for the year 2005/6. It was an unannounced inspection, which started at 2.30pm and took approximately four hours. The inspection took the form of looking through the documentation including the policies and procedures, a tour of the building and talking to service users and a member of staff, and the deputy manager. What the service does well: What has improved since the last inspection? Requirements made at the previous inspection have in general been actioned. This included the ‘individual plans’ for service users being tailored towards goals, aims and aspirations, rather than a summary of events. The administration of medication has improved, staff have all now attended an accredited course relating to the administration of medication. No errors were found in the recording, storage or disposal of medication within the home. Works relating to the condition of the garden have been actioned, thereby allowing for safety and privacy. Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 6 What they could do better: Please contact the provider for advice of actions taken in response to this inspection. The report of this inspection is available from enquiries@csci.gsi.gov.uk or by contacting your local CSCI office. Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 7 DETAILS OF INSPECTOR FINDINGS CONTENTS Choice of Home (Standards 1–5) Individual Needs and Choices (Standards 6-10) Lifestyle (Standards 11-17) Personal and Healthcare Support (Standards 18-21) Concerns, Complaints and Protection (Standards 22-23) Environment (Standards 24-30) Staffing (Standards 31-36) Conduct and Management of the Home (Standards 37 – 43) Scoring of Outcomes Statutory Requirements Identified During the Inspection Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 8 Choice of Home The intended outcomes for Standards 1 – 5 are: 1. 2. 3. 4. 5. Prospective service users have the information they need to make an informed choice about where to live. Prospective users’ individual aspirations and needs are assessed. Prospective service users know that the home that they will choose will meet their needs and aspirations. Prospective service users have an opportunity to visit and to “test drive” the home. Each service user has an individual written contract or statement of terms and conditions with the home. The Commission consider Standard 2 the key standard to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 2,3 and 4 Prior to any new placement commencing, the manager of the home gathers as much information as possible from a variety of sources. A trail period is then initiated before any decision is made concerning the placement. In this way, it is hoped that any new service users will feel that the placement is appropriate for their needs, and that they are not just fitting into an existing vacancy. EVIDENCE: No new service users have been admitted to the home for a number of years and therefore this standard could not be assessed fully. For all the existing service users there was an initial assessment, which had been completed by the manager after gathering information from a variety of sources, including other professionals, friends, family and the service users themselves. There is then a process of introductions, when the prospective new service user comes for tea visits, then overnights and then for a trail period. A meeting is then held to make sure that everyone, and particularly the service user is happy for the placement to start. The home collectively has a range of experience and skills amongst its staff group in order to deliver the service. It is noteworthy that the home has Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 9 recently employed its first male worker, which is seen by the four male service users as positive. Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 10 Individual Needs and Choices The intended outcomes for Standards 6 – 10 are: 6. 7. 8. 9. 10. Service users know their assessed and changing needs and personal goals are reflected in their individual Plan. Service users make decisions about their lives with assistance as needed. Service users are consulted on, and participate in, all aspects of life in the home. Service users are supported to take risks as part of an independent lifestyle. Service users know that information about them is handled appropriately, and that their confidences are kept. The Commission considers Standards 6, 7 and 9 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 6,7,9 and 10 In general, service users are given some everyday choices; therefore this enables them to feel that they can take control of their lives to some extent. Reviews take place on a regular basis, so that changing goals and aspirations can be identified. Some risk assessments are in place but there scope needs to be extended and they need to be updated. EVIDENCE: The service users and the key worker complete three monthly plans regarding their aims, goals and objectives. These plans are then the framework for the annual reviews. It was positive to note that these summaries were completed regularly. A previous requirement that the home must focus their plans so that the goals and objectives are clearly defined has now been achieved and therefore this requirement has been withdrawn. Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 11 Service users have all had their statutory annual reviews in recent months; minutes of these meetings were not available as the majority of the meetings were so recent. These meetings are held by Social Services, and include the service user, the manager, and key worker from Angel Home and key worker from Hallmead. Service users are given the opportunity to make some decisions in their lives; they choose what to wear and what to eat. There are monthly meetings held for service users, the last one was the 12.10.05. The meetings tend to focus food and living in shared accommodation. One of the service users had recently been away for a few days to Blackpool and had been very positive about the experience, it seems that this may have inspired the other service users to go on holiday next year. Risk assessments were in place and had been completed by the manager. However, they were not extensive and did not cover all aspects of living at Angel Home or all the activities that maybe undertaken there. The risk assessments were last updated in September 2004, and therefore need to be updated. A requirement has been made in this regard. Service users are aware that information is held about themselves, but do not feel inclined to read it. Information is kept in the office, and is locked away when the office is not in use. In discussions with a member of staff, he had a clear understanding of the elements of confidently and how to put it into practice. Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 12 Lifestyle The intended outcomes for Standards 11 - 17 are: 11. 12. 13. 14. 15. 16. 17. Service users have opportunities for personal development. Service users are able to take part in age, peer and culturally appropriate activities. Service users are part of the local community. Service users engage in appropriate leisure activities. Service users have appropriate personal, family and sexual relationships. Service users’ rights are respected and responsibilities recognised in their daily lives. Service users are offered a healthy diet and enjoy their meals and mealtimes. The Commission considers Standards 12, 13, 15, 16 and 17 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 12,13,14,15,16 and 17 There are some opportunities for service users to take part in the ordinary aspects of daily living. However, there does not appear to be a premise that service users should be as independent as possible, and therefore inadvertently independence is restricted. EVIDENCE: Service users all still attend Hallmead day centre five times a week. There they attend a range of activities including swimming, bowling and wood work at Oaks Park. Recent statutory reviews of all the service users confirmed the placement at Hallmead and the programme of events undertaken. Last year, none of the service users went away on holiday instead they chose to stay at the home and have day trips. This summer one of the service users went away on holiday for three nights to Blackpool; other service users choose from organised coach trips, but only went away once to Bournemouth. There is a trip to Cadbury World organised for November. The home does access local community facilities. It is within walking distance of Sutton town centre and therefore is within easy reach of the cinema and Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 13 bowling. Service users recently enjoyed a trip to the circus. The home was able to evidence that activities are offered to service users at weekends such as swimming, however they are rarely taken up according to staff. Service users within this home are reported by staff, to be reluctant to take up activities offered; it is the view of staff that they have many ideas but when it comes to the actual day of an activity they will refuse to go. It is difficult to form a judgement on this, as it is not clear if it is to do with service users view; an ethos within the home or expectations of staff. Visitors are welcomed to the home; there are formal occasions such as Christmas and the summer fair. At other times visitors usually telephone prior to a visit or sometimes just drop in. The majority of service users have family that visit, one person has an advocate, and one service users is on the waiting list with ‘Advocacy Partners’. There is a cordless telephone available for service users to use in the bedrooms if they want privacy or alternatively there is a telephone available in the office. Service users are all provided with a key to their bedrooms, although they choose not to use them. In addition, service users do have a lockable drawer in their bedrooms. The front door is not locked, service users would if they chose to able to leave or enter the home at their own will, the door is alarmed however, which would alert staff to someone using the front door. Mealtimes are important in the home; Service users are encouraged to choose their own menu for the week, there is a tendency to choose traditional meals such as fish and chips. An alterative is always available if service users do not like what is on offer. There is a menu board which is updated daily to let service users know what is on the menu that day. Service users are offered a choice of a take away meal on a monthly basis. Service users tend not to go into the kitchen unless it is specifically for a cooking session. Staff were observed making and bringing drinks into the dinning area for service users on their return from the day centre. The kitchen can be accessed by service users although there is a culture that they tend not to use it Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 14 Personal and Healthcare Support The intended outcomes for Standards 18 - 21 are: 18. 19. 20. 21. Service users receive personal support in the way they prefer and require. Service users’ physical and emotional health needs are met. Service users retain, administer and control their own medication where appropriate, and are protected by the home’s policies and procedures for dealing with medicines. The ageing, illness and death of a service user are handled with respect and as the individual would wish. The Commission considers Standards 18, 19, and 20 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 18,19 and 20 Service users receive support, if they require, attending health appointments; the home ensure that health needs are reviewed and recorded on a regular basis. The systems for the administration and recording of medication are generally improved and therefore would minimise the risks to service users. In addition, staff have all recently attended an accredited course regarding the administration of medication, therefore a previous requirement has been withdrawn. EVIDENCE: Angel Home has a small staffing team of five individual staff, and bank staff who work as and when it is necessary. This provides consistency of care. Each individual service user has two designated key workers at any one time. The role of these key workers is to complete an individual plan every three months, which outlines the preferred routines of the service user. Staff were observed respecting privacy by knocking on doors and bathrooms before entering. Each service users had their own toiletries available to them Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 15 in their bedrooms. There was a choice of clean clothes that were available to service users. With regard to health needs, service users seem generally to have their needs met. There are records of health appointments including with the chiropodist and optician; everyone is offered an annual health check by their GP. One service users because of his epilepsy has regular health checks at the local hospital; the home in addition, are monitoring his level of seizures. Only one of the service users is able to self-administer medication, and this, he only does at weekends when he visits his girlfriend. The homes record of the administration of medication appeared accurate. The home receives medication on a weekly basis from the Pharmacist, which are in packs for ease of identification. Paracetmol is stored away appropriately, and prescribed Paracetmol is labelled as such. This was a requirement from the previous inspection and therefore has been withdrawn. In addition, all staff have recently completed an accredited course regarding the administration of medication. Therefore, the previous requirement that staff should complete such training has therefore been withdrawn. Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 16 Concerns, Complaints and Protection The intended outcomes for Standards 22 – 23 are: 22. 23. Service users feel their views are listened to and acted on. Service users are protected from abuse, neglect and self-harm. The Commission considers Standards 22, and 23 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 22 and 23 The home has policies and procedures in place to ensure the protection and well being of the service users. In general, service users felt that their views were heard and acted upon. EVIDENCE: The home has a clear complaints policy, which includes the timescales and the process of the investigation. Each service user had their own copy of the complaints policy in their bedrooms, which was written in plain English, and using Makaton symbols. The home has not received any complaints in the last twelve months, nor has the Commission. Service users during discussions said that they did not have any complaints about the care that they were receiving. The home has a copy of Sutton’s Vulnerable Adults Policy and Procedures. The manager and deputy have both attended recent refresher courses regarding vulnerable adults (July 2004). In discussions with a new member of staff, they were able to show an understanding and awareness of the issues relating to vulnerable adults. Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 17 Environment The intended outcomes for Standards 24 – 30 are: 24. 25. 26. 27. 28. 29. 30. Service users live in a homely, comfortable and safe environment. Service users’ bedrooms suit their needs and lifestyles. Service users’ bedrooms promote their independence. Service users’ toilets and bathrooms provide sufficient privacy and meet their individual needs. Shared spaces complement and supplement service users’ individual rooms. Service users have the specialist equipment they require to maximise their independence. The home is clean and hygienic. The Commission considers Standards 24, and 30 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 24,25,26,27,28,29 and 30 In general, the home is maintained to a reasonable standard with adequate communal space, and individual bedrooms allowing for some privacy. The home is adequately furnished and is clean and hygienic. EVIDENCE: Bedrooms have been recently decorated in consultation with the service users. Each bedroom is a single room, with a bed, chair, wardrobe, chest of drawers, and a large easy chair. All bedrooms have a wash hand basin. Service users had televisions and various audio equipment in their bedrooms. There was some personalisation in the bedrooms, with posters and photographs of family and friends. The back garden is small, although in keeping with the local area. It is dominated by a concrete ramp, which leads from the patio area to the parking at the rear of the building. A previous requirement that the garden area must be improved has been completed and therefore this requirement has been withdrawn. Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 18 The home is equipped with a downstairs toilet, and an upstairs bathroom and toilet. The bath itself does allow for staff to assist with bathing in that it is accessible from all sides. A grab rail has recently been fitted in order to assist with service users independence. A previous requirement that a referral must be made to the Occupational Therapist Department has been competed. However, because of the long waiting list for the service an appointment is still pending. Therefore, unfortunately for the home, this requirement is still outstanding and has been deemed not to have been met. Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 19 Staffing The intended outcomes for Standards 31 – 36 are: 31. 32. 33. 34. 35. 36. Service users benefit from clarity of staff roles and responsibilities. Service users are supported by competent and qualified staff. Service users are supported by an effective staff team. Service users are supported and protected by the home’s recruitment policy and practices. Service users’ individual and joint needs are met by appropriately trained staff. Service users benefit from well supported and supervised staff. The Commission considers Standards 32, 34 and 35 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 32,33 and 34 In general, it appears that the staff team are able to offer the service users a range of experiences and skills. It was positive to note that the home now has a male member of staff working on a part time basis. This does not address the balance totally with four of the five service users being male but is a step in the right direction. Staff undergo an induction process when they are newly appointed, and then are offered a range of courses in order to broaden their knowledge. A requirement has been made that the staff duty rota must reflect accurately who is on duty and when. EVIDENCE: Angel Home has a small staff team of five individuals, who have provided a degree of consistency for the service users. Bank staff are used on occasions, but this is limited. In the main, two people staff the home in the mornings and in the evenings during weekdays. There is one waking night staff. In general, at weekends two members of staff are on duty, each completing a fourteen-hour shift. Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 20 It was positive to note that the home had recently appointed a male member of staff at the home on a part-time basis. This was viewed by the service users as positive. Staff rotas were viewed at random, although in general they reflected the staffing levels required. Two errors were found in one week’s rota identifying who was actually on duty at a particular time. A requirement has therefore been made in this particular regard that staff rotas must reflect who is actually on duty at any given time. Training opportunities were available to all staff at the required level. The member of staff interviewed was able to give a clear description of the induction process that was undertaken and the subsequent training that they had completed. Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 21 Conduct and Management of the Home The intended outcomes for Standards 37 – 43 are: 37. 38. 39. 40. 41. 42. 43. Service users benefit from a well run home. Service users benefit from the ethos, leadership and management approach of the home. Service users are confident their views underpin all self-monitoring, review and development by the home. Service users’ rights and best interests are safeguarded by the home’s policies and procedures. Service users’ rights and best interests are safeguarded by the home’s record keeping policies and procedures. The health, safety and welfare of service users are promoted and protected. Service users benefit from competent and accountable management of the service. The Commission considers Standards 37, 39, and 42 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 37,41 and 42 The manager of the home is experienced, however she is currently lacking the qualification that is required to undertake this position. This is not because of the lack of ability rather the long waiting list for people undertaking such qualifications. In general, it appears that the manager has an open responsive style of management. EVIDENCE: The manager of the home has considerable experience in the care field, including working with people with learning difficulties for nine years, and a further seven years with the elderly. The manager is also the registered owner of the home, which was set up in 1996. A previous requirement that the manager must complete her NVQ Level 4 by 2005 remains outstanding. The manager has enrolled on the course but is still Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 22 on a waiting list and does not have a start date. The manager was able to provide evidence of this. The deputy of the home is an immediate family member of the manager. This relationship has been discussed at length both with the manager and deputy, and with the staff within the home. It does not appear that this relationship has any adverse effect on the running of the home, or upon the care given to the service users. The home takes seriously its responsibilities for the health and welfare of service users and staff. With regard to fire, alarms are checked weekly; drills are undertaken monthly, the last one being on the 4.10.05; external checks were last undertaken on the 1.10.05. Gas installation was checked on 16.11.04; Electrical checks are valid until June 2006. According to the manager, the Legionella testing was completed, in midOctober although a certificate was not available for inspection purposes. A requirement was made that chemicals and other substances hazardous to health currently stored in the laundry room and in the kitchen must be stored away appropriately in a locked facility. Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 23 SCORING OF OUTCOMES This page summarises the assessment of the extent to which the National Minimum Standards for Care Homes for Adults 18-65 have been met and uses the following scale. The scale ranges from: 4 Standard Exceeded 2 Standard Almost Met (Commendable) (Minor Shortfalls) 3 Standard Met 1 Standard Not Met (No Shortfalls) (Major Shortfalls) “X” in the standard met box denotes standard not assessed on this occasion “N/A” in the standard met box denotes standard not applicable CHOICE OF HOME CONCERNS AND COMPLAINTS Standard No 1 2 3 4 5 Score X 3 3 3 X Standard No 22 23 Score 3 3 ENVIRONMENT INDIVIDUAL NEEDS AND CHOICES Standard No 6 7 8 9 10 Score 3 3 X 2 3 Standard No 24 25 26 27 28 29 30 STAFFING Score 3 3 3 3 3 2 3 LIFESTYLES Standard No Score 11 X 12 3 13 3 14 3 15 3 16 3 17 Standard No 31 32 33 34 35 36 Score X 3 2 X X X CONDUCT AND MANAGEMENT OF THE HOME 3 PERSONAL AND HEALTHCARE SUPPORT Standard No 18 19 20 21 Angel Home Score 3 3 3 X Standard No 37 38 39 40 41 42 43 Score 2 X X X 3 2 X DS0000007204.V260803.R01.S.doc Version 5.0 Page 24 Yes Are there any outstanding requirements from the last inspection? STATUTORY REQUIREMENTS This section sets out the actions, which must be taken so that the registered person/s meets the Care Standards Act 2000, Care Homes Regulations 2001 and the National Minimum Standards. The Registered Provider(s) must comply with the given timescales. No. 1. Standard YA9 Regulation 15(2)(b) Requirement The home must review all documentation relating to risk assessments to ensure that it covers all aspects of the service users lives, and that they are updated annually. The home must ensure that it keeps accurate records of the days and times that are actually worked by staff. Immediate The home must ensure that chemicals and other substances hazardous to health are stored away appropriately. Immediate The manager of the home must completed NVQ Level 4 The home must provide aids and adaptations and equipment following an assessment by an occupational therapist, that is suitable for the assessed needs of service users in order to maximise their independence Timescale for action 20/12/05 2. YA29 17(3)(a) 20/10/05 3. YA42 13(4)(a) 20/10/05 4. 5. YA37 YA29 9(2)(b)(i) 23(2)(n) 20/01/06 20/11/05 Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 25 RECOMMENDATIONS These recommendations relate to National Minimum Standards and are seen as good practice for the Registered Provider/s to consider carrying out. No. Refer to Standard Good Practice Recommendations Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 26 Commission for Social Care Inspection Croydon, Sutton & Kingston Office 8th Floor Grosvenor House 125 High Street Croydon CR0 9XP National Enquiry Line: 0845 015 0120 Email: enquiries@csci.gsi.gov.uk Web: www.csci.org.uk © This report is copyright Commission for Social Care Inspection (CSCI) and may only be used in its entirety. Extracts may not be used or reproduced without the express permission of CSCI Angel Home DS0000007204.V260803.R01.S.doc Version 5.0 Page 27 - Please note that this information is included on www.bestcarehome.co.uk under license from the regulator. Re-publishing this information is in breach of the terms of use of that website. Discrete codes and changes have been inserted throughout the textual data shown on the site that will provide incontrovertable proof of copying in the event this information is re-published on other websites. 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