Inspection on 27/09/05 for Beech Street Home

This inspection was carried out on 27th September 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 but made no statutory requirements on the home.

Other inspections for this house

Beech Street Home 01/08/07

Beech Street Home 21/06/06

Beech Street Home 20/05/05

Beech Street Home 14/09/04

Beech Street Home 20/04/04

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

CARE HOMES FOR OLDER PEOPLE Beech Street Home Jarrow Tyne and Wear NE32 5LD Lead Inspector Miss Nic Shaw Unannounced Inspection 27th September 2005 8.45 X10015.doc Version 1.40 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 Beech Street Home DS0000037970.V250577.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 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. Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 3 SERVICE INFORMATION Name of service Beech Street Home Address Jarrow Tyne and Wear NE32 5LD 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) 0191 483 5284 0191 489 8549 South Tyneside MBC Maureen Aziz Care Home 35 Category(ies) of Dementia - over 65 years of age (18), Learning registration, with number disability over 65 years of age (1), Mental of places Disorder, excluding learning disability or dementia - over 65 years of age (3), Old age, not falling within any other category (35), Physical disability over 65 years of age (5) Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 4 SERVICE INFORMATION Conditions of registration: 1. 2. The service may from time to time admit persons between the ages of 60 and 65 years of age. The service user categories listed apply to those living in the home only and no other person should be admitted to the home with an assessment of dementia without prior consultation with the Commission for Social Care Inspection. Date of last inspection Brief Description of the Service: Beech Street Elderly Persons home is a Local Authority purpose built home which is situated in Jarrow. The home is registered for up to 35 residents, some of whom have a dementia type illness. Nursing care is not provided but District Nursing services are accessed as required. Accommodation is over one floor, with level access throughout. Accomodation consists of a number of communal areas, including smoking and non smoking lounges, and a seperate dining area. Residents also have access to a well-equipped reminiscence room, separate hairdressing facility and spacious garden. There is an attractive entrance foyer to the home, which has been enhanced with a water feature, plants and ornaments. There is also a short break wing, which includes a lounge and sepeate dining area, which can offer a service for up to three people. The home is situated on Beech Street which is located close to the busy town centre of Jarrow where facilities such as shops, pubs, GP surgerys and places of worship can be easily accessed. Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. The inspection took place over 8 hours in September 2005 and was a scheduled unannounced inspection. The inspection process involved spending time talking to a number of the people who live in the home as well as the manager, staff, and visitors, and the home’s line manager. A sample of records were examined including care plans, rotas, accident book and fire log book. A tour of the building took place which included all communal areas and a sample of residents bedrooms. The lunchtime meal was also sampled and observations were made of the support the staff offered to residents throughout this process. The judgements made are based on the evidence available on the day of the inspection. The manager stated the people who live in the home prefer to be referred to as residents and this will be reflected throughout the report. What the service does well: What has improved since the last inspection? Prospective residents or their families are now provided with a copy of the Resident Guide. This provides them with information on the services and facilities provided within Beech Street so that they can decide whether or not they wish to move into the home. Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 6 A standard form of contract has been developed. The manager is in the process of providing a copy of this to all of the residents so that they know the terms and conditions of residency. Mealtime arrangements have improved with those residents who require help with their food being discreetly supported by the staff. Some of the records to show that staff have been recruited in a way which ensures that the residents are protected are now held in the home. 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. Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 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 Outcomes Statutory Requirements Identified During the Inspection Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 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 the following standard(s): 1, 2 & 3 Information is available to inform residents that the service will be able to meet their needs. Residents have been issued with a contract, therefore, they know their rights as residents are protected. Each resident’s needs are assessed prior to their move to the home. This helps to ensure that their needs are met at the home and inappropriate admissions are avoided. EVIDENCE: There is a Statement of Purpose and a Resident Guide. An examination of these documents concluded that residents are provided with information on the services and facilities provided at Beech Street. Discussion with the manager concluded that prospective residents or their relatives are now always provided with a copy of the Resident Guide in order to assist them with deciding whether or not they wish to move into Beech Street. Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 9 A standardised contract document has been developed and the manager is in the process of issuing copies of these to all of the residents and their families. Each resident has a social worker’s assessment undertaken prior to their admission to the home. The manager also carries out an individual assessment, which is currently under review, to ensure that the home is suitable for meeting the needs of residents who are accommodated there. Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 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 the following standard(s): 7, 8, 9 & 10 The health and personal care needs recorded in the care plans do not reflect the resident’s current level of need. Some of the medication administration procedures are unsafe. This means that the resident’s health and personal needs are not being adequately met and therefore their welfare is potentially at risk. Arrangements are in place to help preserve resident’s privacy and dignity, however, insufficient staffing levels have impacted on the ability of staff to address these fully. EVIDENCE: Discussion with the manager concluded that there has been no change to the care plan format since the last inspection. The Local Authority have developed a corporate care plan document and the home is waiting for this to be implemented before progress to the care plans can be made. Of the sample of care plans viewed information within them lacked detail and did not provide staff with guidance in relation to what they should do, particularly in those situations where a resident may become verbally or physically aggressive towards them. During the inspection a resident was observed using a pressure Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 11 relieving cushion, however, there was no reference to this in the care plan and discussion with the manager indicated that this particular resident was not at risk from developing pressure sores. A “Waterlow” assessment had been completed for another resident which indicated that they were at risk of developing a pressure sore, however, there was no care plan in place to guide staff of what they should do to prevent this from happening. Residents and relatives spoke positively of the staff and confirmed that the health care needs of the resident’s were adequately met in the home. Comments received included “I’m well looked after” and “I like the staff”. However, it was evident that some of the female residents had not been given support with areas of personal grooming, or support to change their clothing following lunch. Discussion with the manager confirmed that this was as a result of poor staffing levels and the complex needs of the residents currently living in the home. Medication is handled and administered by senior care staff. Medication rounds take place during the morning, at lunch time, at tea time and in the evening. A monitored dosage system is used, whereby the dispensing pharmacist supplies each residents’ medication within a “blister pack”. This contains a series of small pockets that correspond to the four medication rounds of the day, and the seven days of the week for a one month period. Printed ‘medication administration records’ are also supplied by the pharmacist. Medication records examined indicated that on a number of occasions residents had not been given their morning medication as they were asleep. This had occurred on five occasions within a one week period with no action being taken by the manager or senior staff to address this issue. Discussion with the deputy manager indicated that some of the residents do not regularly receive their prescribed medication as they either “refuse” it or “spit it out”. Later discussion with the manager in relation to this issue indicated that for one resident this was being pursued with their GP, however, it was advised that procedures must be put in place to ensure that in all instances residents do not go without their prescribed medication for a number of days. Two signatures were evident on the medication record for all controlled drugs which had been administered. However, discussion with the deputy manager confirmed that although a second staff member signs the medication record, they may not have actually witnessed the medication being administered. As such this medication is not being “controlled” by the home as recommended by the Royal Pharmaceutical Society. An audit of the controlled medication held in stock did not balance with the records maintained. Records examined confirmed that this was as a result of a recording error made by staff, however, had not been identified through the home’s routine auditing systems. There was no evidence on the medication record that residents prescribed creams had been administered. Discussion with deputy manager indicated Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 12 that a separate record of this was maintained and kept in the resident’s bedroom, however, an examination of this confirmed this had not been completed by staff. In addition to this there were some unexplained gaps on the medication administration record although the deputy manager stated that the medication had been administered, as it was not within the “blister pack”. A large number of tablets were stored in a container which were to be returned to the pharmacist. This issue was raised during the last inspection where it was suggested that the manager should implement a system to monitor where and when the medication had been found in order to establish which of the residents were not receiving their prescribed medication. This issue has not been addressed. It was also suggested during the last inspection that a record of the fridge temperature be maintained in order to ensure that medication is stored appropriately. This issue also remains outstanding. Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 13 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 the following standard(s): 12, 13, 14 & 15 Residents are offered a varied menu with wholesome food, which promotes their health and well being. Staff support the residents to exercise choice and they are able to maintain contact with their families and friends. However, there are limited opportunities for social activities and very little for the residents to do in the home. This restricts the residents’ ability to lead stimulating and fulfilling lifestyles. EVIDENCE: A programme of activities has been developed since the last inspection and this was displayed throughout the home. However, discussion with the residents and visitors indicated that although there used to be a variety of activities taking place in the home, such as nail painting, lately this had not been the case. One visitor made the comment that they felt that this was due to there not being enough staff. After lunch, it was evident that there was little for the residents to do and the majority of them spent time “dozing” in the lounges. Discussion with the manager further confirmed that due to insufficient staffing levels being provided to meet the care needs of the current residents it has not been possible for the staff to implement the activities Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 14 programme. There are also limited opportunities for residents to take part in activities outside of the home. Relatives spoken to said that they could visit their family member at any time and were made to feel very welcome by the staff. Residents are able to choose what personal possessions to bring to the home, what to eat at mealtimes as well as being able to choose what clothes to buy from the clothing which is available to purchase from a “clothing agency” which visits the home. Residents commented that the quality of the food is good and that they have a good choice of meals. The lunch time meal was a pleasant, relaxed social occasion where support was undertaken discreetly by staff where this was required. Tureens, and teapots were available on tables and residents were able to help themselves to desired portions of vegetables and cups of tea. Some people preferred to take their meals alone in their rooms and the staff facilitated this. Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 15 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 the following standard(s): 18 The home has adult protection procedures, which ensure that if abuse is suspected or witnessed then appropriate action is taken to safeguard the residents. EVIDENCE: The Local Authority’s Adult Protection Procedure and whistleblowing policy are available within the home, to guide staff on what to do if they have concerns in this area. The majority of the staff have had training in relation to this and residents spoken to said that they felt “safe” living in the home. Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 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 the following standard(s): 19 & 26 The home is clean, warm and well maintained offering residents a homely and safe environment in which to live. EVIDENCE: All communal areas and a selection of resident’s bedrooms were viewed during the inspection. Some of the resident’s bedrooms have been redecorated and refurbished since the last inspection and a new front door has been fitted to the entrance of the home. The locking device fitted to this promotes the security of the building as it is no longer possible for visitors to walk into the home unannounced. The lighting in this area has also been improved. Clear notices have now been fitted to WC’s so that residents can easily find these areas. The cleaning regime of the home is effective making sure that residents live in pleasant well kept surroundings. Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 17 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 consider all the above are key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 27, 29 & 30 The deployment and number of staff on all shifts does not ensure that residents are supported or their needs effectively met. Staff shortages has also meant that staff have not been able to attend pre-arranged training courses which may compromise their ability to carry out their jobs effectively. Staff recruitment practices provide safeguards to offer protection to people living in the home. EVIDENCE: Discussion with the manager and deputy manager indicated that staffing levels within the home had recently not been sufficient to meet the complex care needs of the residents. At present one resident living in the home requires the assistance of two staff at all times with personal care needs. This resident is reported by staff to be “demanding” of staff time, which means that they cannot effectively meet the needs of the other people living in the home. As a result of this the manager said that she felt that the morale of the staff team was poor. The lack of staff was particularly evident after lunch when staff were not visible for periods of time leaving all of the residents unsupervised. The home’s line manager was present for part of the inspection and these concerns were discussed with him. Given the high care needs of the residents and the risk assessment that identified that one resident requires the assistance of two staff at all times an immediate requirement notification was issued to the manager relating to reviewing and increasing staffing levels to Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 18 reflect the needs of the residents. The Commission has since been advised that an additional member of staff has been provided throughout the day. A sample of staff files were examined which confirmed that a thorough recruitment process is carried out which includes obtaining an Enhanced Criminal Records Bureau check and two written references, one of which is from the last employer. Training records examined indicated that some of the staff had not recently had training in relation to health and safety issues such as food hygiene, fire safety and moving and handling. The manager stated that moving and handling training had been arranged for five of the staff that week, however, due to staff shortages it was deemed necessary to cancel this training. These issues were discussed with the home’s line manager and action must be taken to address them without further delay. The majority of staff have not received in-depth training in relation to the needs of people with dementia. This was discussed during the last inspection where the manager indicated that she had recognised this as a need and was in the process of arranging for ten of the staff to complete an NVQ level 2 qualification in the care of people with dementia. However, discussion with the manager confirmed that no progress has been made in relation this. Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 19 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 31, 33, 35 and 38 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 33, 35 & 38 Residents health and safety is generally well promoted. Residents financial interests are safeguarded, however, systems need to be put in place in order to ensure that the views of residents are used to influence the development of the service. EVIDENCE: The manager and staff obtain feedback from the relatives by using comments cards which are left on display in the entrance foyer of the home and can be completed anonymously. However, there is no formal quality assurance system to obtain the views of residents, relatives and visiting professionals. This issue was raised during the last inspection and remains an outstanding requirement. A sample of residents personal allowance records maintained by the home were examined. For each purchase made by the staff, on behalf of the Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 20 residents, receipts and two staff signatures are maintained. Where the residents are able they are encouraged to sign the cash transaction sheet themselves. Secure facilities are provided for the safe-keeping of money and valuables on behalf of the residents. A record of accidents is maintained and systems are in place to monitor the occurrence of these. Guidance has been sought from other professionals, such as the GP, where necessary. The fire log book was examined which indicated that fire instruction and fire equipment checks have been carried out as recommended by the Fire Authority. Discussion with the manager indicated that where appropriate residents are supported by staff to look after their own cigarettes. Discussion was held with the manager of the need to include this within the home’s fire risk assessment. The bathwater temperature on the short term care wing was tested and found to be 47 degrees centigrade. This needs to be maintained at 43 degrees centigrade in order to ensure that there is no risk of scalding and an immediate requirement notification was issued to the manager in relation to this issue. As mentioned earlier in the report some of the staff require up-to-date training in relation to health and safety issues. Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 21 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. 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 Standard No Score 1 2 3 4 5 6 ENVIRONMENT Standard No Score 19 20 21 22 23 24 25 26 3 3 3 X X X HEALTH AND PERSONAL CARE Standard No Score 7 2 8 3 9 1 10 2 11 X DAILY LIFE AND SOCIAL ACTIVITIES Standard No Score 12 2 13 3 14 3 15 3 COMPLAINTS AND PROTECTION Standard No Score 16 X 17 X 18 2 3 X X X X X X 3 STAFFING Standard No Score 27 1 28 X 29 3 30 2 MANAGEMENT AND ADMINISTRATION Standard No 31 32 33 34 35 36 37 38 Score X X 2 X 3 X X 2 Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 22 Are there any outstanding requirements from the last inspection? Yes 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 OP7 Regulation 15(1) Requirement Timescale for action 31/12/05 2 OP9 13(2) Care plans must be developed to provide staff with detailed guidance on the action they need to take to address the residents assessed needs. (Timescale not met 30/09/05). Systems must be put in place to 29/09/05 ensure that all residents are recieving their prescribed medication. This must include an effective system to monitor the frequency and location of those tablets “found” by staff. Two staff must witness the administration of controlled drugs. There must be no unexplained gaps on the medication administration record. A record of the fridge temperatures must be maintained. Steps must be taken to preserve the dignity of the residents. Arrangements must be in place for the residents to engage in local social, and community activities. Staffing levels must be kept DS0000037970.V250577.R01.S.doc 3 4 OP10 OP12 12(4)(a) 16(2)(m) 30/11/05 31/12/05 5 OP27 18(1)(a) 27/09/05 Page 23 Beech Street Home Version 5.0 6 7 8 OP30 OP30 OP33 18(1)(a) 18( 1 )( c)(i0 24 9 10 OP38 OP38 23(4) 13(4)( c ) under review and adjusted to reflect the needs of the residents. Staff must receive training in relation to health and safety matters. Staff must receive training in relation to the needs of people with dementia. Systems must be put in place to obtain the views of residents and their relatives.(Timescale not met 30/09/05). All potential fire hazards must be identified within the fire risk assessment. Bathwater temperatures must be maintained at 43 degrees centigrade. 31/12/05 31/12/05 31/03/05 31/10/05 27/09/05 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 Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 24 Commission for Social Care Inspection South of Tyne Area Office Baltic House Port of Tyne Tyne Dock South Shields NE34 9PT 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 Beech Street Home DS0000037970.V250577.R01.S.doc Version 5.0 Page 25 - Please note that this information is included on www.bestcarehome.co.uk under license from the regulator. 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