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Inspection on 12/04/05 for Ashcroft Rest Home

Also see our care home review for Ashcroft Rest Home for more information

This inspection was carried out on 12th April 2005.

CSCI has not published a star rating for this report, though using similar criteria we estimate that the report is Good. 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 but made no statutory requirements on the home.

What follows are excerpts from this inspection report. For more information read the full report on the next tab.

What the care home does well

The proprietors work in the home on a daily basis. One of the proprietors is the home`s manager. The proprietors are supported by a committed staff team. Service users and their relatives, who were interviewed as part of inspection, were complimentary about the services offered at the home. The home has a relaxed atmosphere.

What has improved since the last inspection?

Since the last inspection the proprietors have introduced a new care planning process. Whilst the implementation has not been fully completed there have been significant improvements over the previous documentation.

What the care home could do better:

We would like to see a significant improvement in the quantity and quality of activities provided for service users. Decorative standards could be improved to create a brighter atmosphere.

CARE HOMES FOR OLDER PEOPLE Ashcroft Rest Home 27-29 Chadwick Road Leytonstone London E11 1NE Lead Inspector Glen Baker Unannounced Inspection 12th April 2005 at 10:00am 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 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 Older People. 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. Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 3 SERVICE INFORMATION Name of service Ashcroft Rest Home Address 27-29 Chadwick Road, Leytonstone, London, E11 1NE Telephone number Fax number Email address Name of registered provider(s)/company (if applicable) Name of registered manager (if applicable) Type of registration No. of places registered (if applicable) 020 8530 6072 Ms Hyacinth Valeska SandilandsMrs Neva Bernice Gilpin Ms Hyacinth Valeska Sandilands Care Home 15 Category(ies) of Old age, not falling within any other category registration, with number (15) of places Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 4 SERVICE INFORMATION Conditions of registration: Date of last inspection 7th December 2004 Brief Description of the Service: Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. The inspection took place on 10/04/05 and was unannounced. The home’s manager, who is also one of the proprietors, was present throughout the inspection. The inspector also had the opportunity of speaking with service users and their relatives and members of the staff team. To assist in the inspection of the home a number of policies, procedures and other documents were inspected. What the service does well: What has improved since the last inspection? What they could do better: We would like to see a significant improvement in the quantity and quality of activities provided for service users. Decorative standards could be improved to create a brighter atmosphere. Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 6 Please contact the provider for advice of actions taken in response to this inspection. The full report of this inspection is available from enquiries@csci.gsi.gov.uk or by contacting your local CSCI office. Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 7 DETAILS OF INSPECTOR FINDINGS CONTENTS Choice of Home (Standards 1–6) Health and Personal Care (Standards 7-11) Daily Life and Social Activities (Standards 12-15) Complaints and Protection (Standards 16-18) Environment (Standards 19-26) Staffing (Standards 27-30) Management and Administration (Standards 31-38) Scoring of Standards Statutory Requirements Identified During the Inspection Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 8 Choice of Home The intended outcomes for Standards 1 – 6 are: 1. 2. 3. 4. 5. 6. Prospective service users have the information they need to make an informed choice about where to live. Each service user has a written contract/ statement of terms and conditions with the home. No service user moves into the home without having had his/her needs assessed and been assured that these will be met. Service users and their representatives know that the home they enter will meet their needs. Prospective service users and their relatives and friends have an opportunity to visit and assess the quality, facilities and suitability of the home. Service users assessed and referred solely for intermediate care are helped to maximise their independence and return home. The Commission considers Standards 3 and 6 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 1,3,5. We were satisfied that the proprietors had developed a Statement of Purpose and Service User Guide that outlined the services that were offered within the home and the philosophy of care that underpinned the services that were provided. The homes admission procedure states that all service users must be fully assessed before admission to the home. EVIDENCE: The Service User Guide and Statement of Purpose were in place and these would assist any prospective service user to make an informed choice about the home prior to admission. Although there have been no admissions since the last inspection relatives of current residents have confirmed that visits to the home were made by both residents and relatives prior to admission. Relatives spoken to as part of inspection confirmed that the choice that had been made had been a positive one in respect of Ashcroft. The proprietors have introduced a new care planning process which includes new assessment documentation. As there have been no new admissions since Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 9 the last inspection, and since the new process has been introduced, its overall effectiveness has yet to be tested. Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 10 Health and Personal Care The intended outcomes for Standards 7 – 11 are: 7. 8. 9. 10. 11. The service user’s health, personal and social care needs are set out in an individual plan of care. Service users’ health care needs are fully met. Service users, where appropriate, are responsible for their own medication, and are protected by the home’s policies and procedures for dealing with medicines. Service users feel they are treated with respect and their right to privacy is upheld. Service users are assured that at the time of their death, staff will treat them and their family with care, sensitivity and respect. The Commission considers Standards 7, 8, 9 and 10 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 7, 8, 9, 10, 11. There have been improvements in the care planning process although the new care planning methodology has yet to be fully implemented. The proprietors must ensure that the new care plans are fully completed, regularly reviewed, updated and are shared with residents. The proprietors have experienced difficulties in securing the services of GPs, since the recent death of a local GP. Medication procedures were seen to be satisfactory. Medication records and storage facilities were inspected and were satisfactory. Residents confirmed they were treated with respect. The proprietors and staff aim to offer a home for life and approach death and dying in a positive way. EVIDENCE: The home is in the process of introducing new care planning documentation. Not all records have been completed. The proprietors must ensure that all documentation is fully completed and the records updated on a day-to-day basis and appropriately reviewed. Daily records must relate to the aims of the care plan to show how and when the care plan is achieved. Care plans must be accessible to and used by all staff as part of the day-to-day work with residents. Residents must be part of the care planning process and where possible should indicate their participation/agreement by signing the relevant Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 11 documentation. Where appropriate, relatives could/should be involved in the process. Residents personal care needs are identified within the care plan. Continence advice is sought initially through the district nurse. Continence awareness training is provided by the manufacturers of continence supplies. A record is made of meals provided at the home. Menus are monitored to ensure they couldnt healthy diet, fresh fruit is always available. Residents weights are monitored and recorded in the care plan. Residents are invited to participate in an armchair exercise on a regular basis. Medication procedures and records were inspected and found to be satisfactory. Both proprietors are qualified nurses and are required to maintain the professional standards of the Nursing and Midwifery Council. All personal care is provided in private and behind closed doors. Residents continue to enjoy the same rights as other Elders living in the community. On the day of inspection and member of staff was assisting residents with their postal votes for the general election. The home has a policy in respect of terminal care. The new care plan documentation can record residents wishes concerning terminal care and arrangements after death. This needs to be completed in respect of all residents. Where specific religious or cultural rights must be observed staff made aware of these are to the care plan and directly by the proprietors. Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 12 Daily Life and Social Activities The intended outcomes for Standards 12 - 15 are: 12. 13. 14. 15. Service users find the lifestyle experienced in the home matches their expectations and preferences, and satisfies their social, cultural, religious and recreational interests and needs. Service users maintain contact with family/ friends/ representatives and the local community as they wish. Service users are helped to exercise choice and control over their lives. Service users receive a wholesome appealing balanced diet in pleasing surroundings at times convenient to them. The Commission considers all of the above key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 12, 13, 14, 15 Residents of the home are able to exercise some choice around the care they receive in the home. There was little evidence of a programme of social and leisure activities within the home. The proprietors must make arrangements for a range of meaningful activities to be undertaken. Residents should be involved in the selection of activities. EVIDENCE: Residents are able to make choices about the time that they rise in the morning and retire at night. Residents were involved in making choices about their meals. Residents were complimentary about the quality of catering in the home. The inspection covered the lunchtime period when the main meal of the day is served. The food prepared was wholesome and plentiful. Hot and cold drinks and snacks are available throughout the day on request. Records are kept of food provided. Residents are able to have visitors as and when they wish. On the day of the inspection there were visitors in the home. Visitors confirmed that they were made welcome at the home. On the day of the inspection one member of staff were seen to be assisting residents with their postal votes and in the afternoon there was an attempt to initiate some community singing. The inspector was told that visits from members of a local church occur on a regular basis. Activities appeared to be organised on an ad hoc basis and with limited resources. As part of the care Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 13 planning process key workers should try to identify activities and leisure interests that residents would like to pursue. The proprietors must make arrangements for activities to be provided within the home. Most residents are assisted by relatives to manage their financial affairs. Relatives also act as advocates in most cases but advocacy services can be arranged as required. Residents are able and are encouraged to bring personal possessions with them to make their rooms more homely. Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 14 Complaints and Protection The intended outcomes for Standards 16 - 18 are: 16. 17. 18. Service users and their relatives and friends are confident that their complaints will be listened to, taken seriously and acted upon. Service users’ legal rights are protected. Service users are protected from abuse. The Commission considers Standards 16 and 18 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 16, 17, 18 There have been no complaints since last inspection. Relatives spoken to were aware of these complaints procedure. Residents have the same legal rights as elders in the community. The home has an adult protection policy and procedure. In one case a possible injury had not been appropriately investigated. EVIDENCE: The complaints record was inspected. There had been no complaints since last inspection. The complaints procedure is detailed in the Statement of Purpose and service user guide. Staff were aware of their responsibilities for reporting complaints. Residents can be supported by relatives or advocates if they wish to use the procedure. Residents have the same legal rights as elders in the community. All residents are appropriately added to the electoral roll after confirmation that they are to remain at the home on a permanent basis. On the day of the inspection service users were being supported to complete their postal votes for the general election when they wish to do this. In most cases residents’ relatives will advocate for them although advocacy can be arranged through the Social Services Department or by other independent advocacy services. The home has an adult protection policy and procedure. Staff undertake training in this as part of the NVQ training and induction training. Care records inspected indicated that unexplained bruising had been found on one resident but this had not been followed up. The proprietors must ensure that any unexplained injuries are appropriately investigated. The proprietors must ensure that all staff receive regular training, support and supervision in the area of adult abuse and protection and that this must be recorded. Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 15 In most cases relatives assist residents in the management of their finances. The proprietors do not manage residents finances on their behalf. Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 16 Environment The intended outcomes for Standards 19 – 26 are: 19. 20. 21. 22. 23. 24. 25. 26. Service users live in a safe, well-maintained environment. Service users have access to safe and comfortable indoor and outdoor communal facilities. Service users have sufficient and suitable lavatories and washing facilities. Service users have the specialist equipment they require to maximise their independence. Service users’ own rooms suit their needs. Service users live in safe, comfortable bedrooms with their own possessions around them. Service users live in safe, comfortable surroundings. The home is clean, pleasant and hygienic. The Commission considers Standards 19 and 26 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 19, 20, 21, 22, 23, 24, 25, 26 The home is situated in quiet residential area and is accessible by public transport. The home consists of two former domestic dwellings. The home blends well into its surroundings. The home provides a variety of bedroom and communal areas on the ground floor and further bedrooms are accessible by stairs and stair lift to the upper floors. The décor throughout the home is basic but the home was clean and odour free on the day of inspection. The home has in 11 bedrooms 5 of which have ensuite facilities. Residents are able to personalise their own rooms. The home has a garden to the rear that is accessible to residents. EVIDENCE: The home has three communal areas, the lounge area, a dining area and an activities area. Accessible toilet facilities are available on the ground floor. The rear garden is accessible through sliding doors leading from the activities area. The home is furnished with domestic style furniture throughout. The lounge has a television and audio system and seating arrangements are determined by the location of the items. A ground floor office adjacent to the Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 17 dining room and activities room is used by the proprietors and allows both supervision of the ground floor and an opportunity for residents, relatives and staff to talk to the proprietors in private. The office can also be used for residents to have private discussions with friends, relatives or advisers. A sample of bedrooms were inspected. Bedrooms were homely and had been personalised by residents. Currently the home has one shared room. The proprietors have proposed that this will become a single bedroom when an appropriate opportunity arises. Bathroom and toilet facilities are basic but functional. The home appears to have appropriate manual handling equipment/aids. A new water tank has been installed and a legionella assessment has been undertaken since last inspection. Laundry facilities were inspected and found to be satisfactory. Wheelchair access is available to the ground floor, including grounds, only. Some redecoration had occurred since the last inspection. The grounds to the rear of the building are divided between a small patio area, a lawn and well-stocked borders. The grounds are used in the warmer and drier months. The proprietor’s attention was drawn to some debris close to the rear fence of the property. This must be removed. Access pathways to the sides of the building should be kept clear for health and safety reasons. Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 18 Staffing The intended outcomes for Standards 27 – 30 are: 27. 28. 29. 30. Service users needs are met by the numbers and skill mix of staff. Service users are in safe hands at all times. Service users are supported and protected by the home’s recruitment policy and practices. Staff are trained and competent to do their jobs. The Commission considers Standards 27, 29, and 30 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 27, 28, 29, 30 On the day of inspection the home of staff that the level that enabled residents needs to be met. The rota showed that appropriate levels of staffing were provided throughout the week. The home has met the requirement to have a minimum ratio of 50 trained members of care staff (NVQ level 2 or equivalent). The proprietors are both registered nurses and are accountable to both the Nursing and Midwifery Council and the Commission for Social Care Inspection for their professional standards. The staff team have a variety of experiences that they bring to their caring role. EVIDENCE: There are a minimum of two members of care staff on duty at all times. In addition the home has domestic staff. One of the proprietors is also registered manager of the home. Both the proprietors work in the home on a full-time basis. The home has had a training needs assessment undertaken by the Waltham Forest Social Care Partnership. The proprietors are developing a training plan based on this assessment. The standards required of the minimum ratio of 50 of trained members of care staff (NVQ level 2 or equivalent) is achieved by 2005. The home has already met this target. The home has an appropriate recruitment policy and procedure. A sample of personal records was inspected and found to be generally satisfactory. The proprietors are reminded that Criminal Records Bureau disclosures are not transferable from one organisation to another and must be obtained, by the proprietors, for all staff prior to the commencement of employment. Staff are Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 19 employed in accordance with the code of conduct in practice set by the General Social Care Council. Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 20 Management and Administration The intended outcomes for Standards 31 – 38 are: 31. 32. 33. 34. 35. 36. 37. 38. Service users live in a home which is run and managed by a person who is fit to be in charge, of good character and able to discharge his or her responsibilities fully. Service users benefit from the ethos, leadership and management approach of the home. The home is run in the best interests of service users. Service users are safeguarded by the accounting and financial procedures of the home. Service users’ financial interests are safeguarded. Staff are appropriately supervised. 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 and staff are promoted and protected. The Commission considers Standards 33, 35 and 38 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 31, 32, 33, 34, 35, 36, 37, 38 The proprietors of work full-time in the home. The proprietors are both registered nurses. There are inconsistencies between the approaches and styles of two proprietors and staff have reported that this can cause some tension. The proprietors should try to present a more united front and more consistent approach to the management of the home. Overall the atmosphere in the home is relaxed and casual. The proprietors are in the process of completing the annual development plan for the home and this will be inspected at next inspection. An inspection of financial records indicated that the home continues to be financially secure. The home has a health and safety policy. Some door release mechanisms were not working properly on the day of the inspection and these must be repaired/replaced as a matter of urgency. EVIDENCE: Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 21 The proprietors are both registered nurses and have considerable experience both in the nursing and care sectors. One of the proprietors is also the registered manager and is currently undertaking the registered managers award. Staff reported in this inspection, and have reported in the past, that there are inconsistencies in the management style and approach of two proprietors, who both work in the home full-time. Residents and staff will benefit from greater co-operation and consistency between them. The atmosphere in the home, on the day of inspection, was relaxed. Residents and relatives spoken to confirmed that there was good and regular communication with the proprietors. The accounts of the home indicated that the business is financially secure. Appropriate insurance documentation was in place. The proprietors of preparing the annual development plan for the home which will be inspected at the next inspection. The proprietors look after monies on behalf of service users. Records of all transactions are maintained. A sample of the accounts was inspected and found be satisfactory. Monies are kept securely in the office. Most service users are supported by the families in financial matters. Records indicate that staff have undertaken training in moving and handling, fire safety and first aid. Appropriate manual handling equipment appeared to have been provided. CoSHH data sheets were available for inspection. Items covered by CoSHH regulations were appropriately stored. Landlords gas safety certificate was available for inspection. Electrical and portable appliance certificates were available for inspection. Legionella risk assessments have been undertaken. A number of automatic door closer units were not working on the day the inspection and fire doors had been propped open. These must be repaired or replaced as a matter of urgency. Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 22 SCORING OF OUTCOMES This page summarises the assessment of the extent to which the National Minimum Standards for Care Homes for Older People have been met and uses the following scale. Where there is no score against a standard it has not been looked at during this inspection. 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 ENVIRONMENT Standard No 1 2 3 4 5 6 Score Standard No 19 20 21 22 23 24 25 26 Score 3 x 3 x 3 N/A HEALTH AND PERSONAL CARE Standard No Score 7 2 8 3 9 3 10 3 11 3 DAILY LIFE AND SOCIAL ACTIVITIES Standard No Score 12 2 13 3 14 3 15 3 COMPLAINTS AND PROTECTION 2 3 3 3 3 3 2 3 STAFFING Standard No Score 27 3 28 3 29 2 30 3 MANAGEMENT AND ADMINISTRATION Standard No 31 32 33 34 35 36 37 38 Score Standard No 16 17 18 Score 3 3 2 3 2 3 3 3 3 2 2 Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 23 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. 2. Standard 7 12 Regulation 12 16 Requirement Newly introduced care plans must be fully completed and regularly reviewed. As part of the care planning process key workers must identify activities and leisure interests that residents would like to pursue. The proprietors must make arrangements for activities to be provided within the home. The proprietors must ensure that any unexplained injuries are appropriately investigated. Debris close to the rear fence of the property must be removed. Access pathways to the sides of the building should be kept clear for health and safety reasons. Automatic door closers must be repaired or replaced. Criminal Records Bureau disclosures are not transferable from one organisation to another and must be obtained, by the proprietors, for all staff prior to the commencement of employment. The proprietors must ensure that all care plans are fully completed and regularly reviewed. G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Timescale for action 30/09/05 31/12/05 3. 4. 18 19 12 23 Immediate 31/07/05 5. 6. 25 29 23 19 immediate immediate 7. 37 15 30/09/05 Ashcroft Rest Home Version 1.20 Page 24 8. 38 23 Automatic door closers must be repaired or replaced. immediate RECOMMENDATIONS These recommendations relate to National Minimum Standards and are seen as good practice for the Registered Provider/s to consider carrying out. No. 1. Refer to Standard 32 Good Practice Recommendations The proprietors should work to reduce inconsistencies between their approaches and styles. Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 25 Commission for Social Care Inspection 4th Floor, Gredley House 1-11 Broadway, Stratford London E15 4BQ 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 Ashcroft Rest Home G56 G06 S7230 Ashcroft Rest Home V220833 120405 Stage 4.doc Version 1.20 Page 26 - 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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