Inspection on 22/08/06 for Friary Lodge

This inspection was carried out on 22nd August 2006.

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 made no statutory requirements on the home as a result of this inspection and there were no outstanding actions from the previous inspection report.

Other inspections for this house

Friary Lodge 14/08/07

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

CARE HOMES FOR OLDER PEOPLE Friary Lodge 177 Friern Barnet Lane Whetstone London N20 0NN Lead Inspector Mr David Hastings Key Announced Inspection 22nd August 2006 09:30 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 Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 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. Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 3 SERVICE INFORMATION Name of service Friary Lodge Address 177 Friern Barnet Lane Whetstone London N20 0NN 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) 020 8445 4756 020 8445 4756 Mrs Fidelma Joan Walsh Mr Kevin John Walsh Mrs Fidelma Joan Walsh Care Home 15 Category(ies) of Old age, not falling within any other category registration, with number (15) of places Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 4 SERVICE INFORMATION Conditions of registration: Date of last inspection 9 February 2006 Brief Description of the Service: Friary Lodge is a registered care home for fifteen older service users. The home is privately owned with the newly registered manager also being the registered provider jointly with her husband. The last manager/provider has retired and the new manager/provider took over the running of the home in February 2006 after an induction/handover period of four months. The home is a large converted three storey domestic premises that includes a ground floor annexe. The communal facilities are on the ground floor and include a large lounge with adjoining conservatory, dining room and kitchen. The laundry and managers office are also located on the ground floor. There are nine service user bedrooms: five on the ground floor, two with en-suite; one single and one shared double on the first floor and three on the second floor, one of the latter with en-suite. There are an additional five shower or bathrooms with WCs and a single WC, spread throughout the home and convenient to service user bedrooms. There is a stair lift to facilitate access to the first and second floors although the home can only accommodate wheelchair users on the ground floor. The home has a large well-kept rear garden that service users can enjoy when they wish. The home is well served by public transport and is situated in a pleasant residential area of Whetstone and is close to Friary Park, local shops and other community services. The stated overall aim of the home is to enable elderly people to lead dignified, independent and fulfilled lives in safety and comfort; also in varying degrees for those who need it, daily help with personal care. The current scale of charges range from £480 to £520 per week. A copy of this report is available on the CSCI website or/and from the home. Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. This announced inspection took place on Tuesday 22nd August 2006 and lasted six and a half hours. Residents that the inspector spoke with were very positive about the new manager. The inspector spoke with six residents and three staff. A tour of the premises took place and case notes were examined. Twelve comment cards were sent to the CSCI from relatives prior to the inspection as well as two comment cards from health care professionals. All the feedback from relatives and health care professionals was positive about the care provided by the home. Relatives commented that staff treated residents with respect and dignity and another relative described the home as “exceptionally well run”. What the service does well: What has improved since the last inspection? What they could do better: Ten new requirements and two immediate requirements were issued as a result of this inspection. The new manager must develop more robust polices and procedures in relation to care planning, staff training and recruitment, quality assurance and fire safety. Two requirements have been issued in relation to medication to ensure the continued safe administration of medication. Fire door guards and fire call points must be checked weekly. Two recommendations have been issued regarding equality and diversity within the home’s statement of purpose and providing an overview of staff training to ensure that all staff receive the training they need to underpin their knowledge. The two immediate requirements relate to fire safety at the home. The inspector is confident that the manager will comply with these requirements within the timescales given. Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 6 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. Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 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 Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 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 and 3 (6 not applicable) Quality in this outcome area is good. This judgement has been made using available evidence including a visit to this service. The manager makes sure that all potential service users’ needs are assessed and that these needs can be met by the home before the service user moves in. EVIDENCE: The home’s statement of purpose and service user guide have been updated by the newly registered manager. Both documents contained the information required by Standard 1 of the National Minimum Standards for Older People. The inspector recommended that the manager review the home’s statement of purpose in relation to equality and diversity. This would ensure that the home’s statement of purpose reflects the diverse nature of the local community. One new service user has recently moved into the home. Records indicated that a full assessment had been undertaken prior to the service user moving in and this assessment covered all the required elements of Standard 3 of the National Minimum Standards for Older People. The service user commented, “From the first I felt secure”. Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 9 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 and 10 Quality in this outcome area is good. This judgement has been made using available evidence including a visit to this service. Staff understand the needs of the service users at the home however care plans must be more holistic in approach. Service users have good access to health care professionals. Service users receive the correct medication at the right times by appropriately trained staff. Service users are treated with respect and their right to privacy is upheld. EVIDENCE: It was clear from discussion with the manager and staff that they understood and were able to meet the needs of service users at the home. However this knowledge and information was not sufficiently detailed in individual care plans. The manager informed the inspector that she would be redesigning the care plans to ensure they are more holistic. A requirement has been made that care plans are developed to incorporate all the identified needs of service users, including social and emotional needs, and that these plans give clear information to staff on how these needs are to be met. There was evidence from the plans that service users have good access to health care professionals such as doctors, chiropodists and dentists. Service Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 10 users that the inspector spoke with confirmed this. The manager informed the inspector that the doctor visits the home every week. Records in relation to the receipt, administration and disposal of medication were examined. All these records were satisfactory. Two new requirements have been issued concerning medication in general. A picture of each service user must be attached to their corresponding medication chart. A list of all staff able to administer medication must be made which gives a sample of their signature as well as the date of their medication training. Service users that the inspector spoke with said the staff were very respectful. Interactions observed between staff and service users confirmed this. Staff were seen knocking on service user’s doors before entering. Staff interviewed were able to give examples of how they maintain service users’ privacy and dignity at the home. Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 11 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 and 15 Quality in this outcome area is good. This judgement has been made using available evidence including a visit to this service. Service users can choose from a range of activities provided by the home and are encouraged to be as independent as possible and exercise choice and control over their lives. Visitors to the home are encouraged and welcomed. Service users receive a wholesome and appealing balanced diet in pleasing surroundings. EVIDENCE: During the inspection staff were carrying out a number of activities with service users including exercises and games. Birthdays are always celebrated and the cook was making a cake for a service user’s forthcoming birthday. Outside entertainers are hired by the manager every two to three months. The manager informed the inspector that some service users go out of the home on a regular basis. Relatives commented that staff encourage service users to take part in stimulating activities. Service users confirmed that they were happy with the activities put on by the home. Feedback received from visitors confirmed that they were made welcome by staff when they visited. Some regular visitors to the home are invited to lunch with the service users. The record of visitors to the home indicated that service users were able to have visitors at any reasonable time. Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 12 Throughout the inspection staff were observed offering choices to service users in terms of what they wanted to do and the registered manager was able to demonstrate a good knowledge of service users ability to manager their own money and whether another individual, such as a solicitor or family member was involved. Service users confirmed that they were offered choice and one service user commented that staff, “let you be your own boss”. A newly devised menu was seen and appeared to be nutritionally balanced. A record of meals served is kept and was seen to record a range of balanced meals. A cook is employed at the home on weekdays and was spoken to independently. The kitchen was clean and tidy with food stored appropriately. Daily records of fridge and freezer temperatures were seen and were satisfactory. Service users stated that the food provided was like “home cooking” and the cook was aware of likes and dislikes and any special diets needed. Service users confirmed that there was always enough to eat. On the day of the unannounced inspection the cook was preparing lamb casserole. Staff were observed sitting with service users and offering discreet assistance when required. Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 13 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): 16 and 18 Quality in this outcome area is good. This judgement has been made using available evidence including a visit to this service. Service users are aware of how to make a compliant if they need to. Service users are protected from abuse by clear policies and procedures. EVIDENCE: The home has a satisfactory complaints procedure that meets the requirements of this standard. A copy of the procedure was also seen in the service user guide and on display in the home. The manager stated that no complaints have been received since the last inspection. Service users that the inspector met said they had no complaints about the home but knew who to talk to if they did. The home has practical guidance for staff regarding adult protection and evidence was seen that most staff have attended adult protection training. A requirement has been issued that all staff at the home must undertaken adult protection training. Staff that the inspector interviewed had a good understanding of the types of abuse and what to do if they witnessed abusive practice occurring at the home. The home has a copy of the local authority’s Adult Protection procedures. Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 14 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 and 26 Quality in this outcome area is good. This judgement has been made using available evidence including a visit to this service. Service users live in a clean and well-maintained environment. EVIDENCE: The inspector identified that the physical standards at the home are good. There is evidence of maintenance and ongoing re-decoration work with an attractive and comfortable environment being provided for service users. It was evident to the inspector that the building had been regularly redecorated and that the furnishings and fittings were kept clean and tidy. There is a large, cultivated garden to the rear, which is very well maintained. The home was clean and tidy. The laundry is located in a separate building at the rear of the home and the washing machine has the required sluice cycle programme. There are satisfactory procedures in place to deal with soiled laundry. Service users commented that the home was always clean. Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 15 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, 28, 29 and 30 Quality in this outcome area is adequate. This judgement has been made using available evidence including a visit to this service. The service users’ needs are well met by a dedicated and caring staff team. All staff at the home must have a satisfactory CRB disclosure that clearly states they are employed by Friary Lodge. Continued emphasis must be placed on staff training and more staff must be trained at NVQ level 2 or equivalent. EVIDENCE: A satisfactory staff rota was seen that showed two care staff on duty on the morning shift, two care staff and one senior on duty on the afternoon shift and one waking and one sleeping-in staff at night. The home employs one cook and one domestic. Service users that the inspector spoke with said they were satisfied with the staffing levels at the home. Service users said the staff were very nice and respectful. Nine staffing files were examined. Although these all contained most of the information required not all had CRB disclosures completed for working at this service. CRB disclosures are no longer transferable from past employers. A requirement has been issued that all staff employed by Friary Lodge must have a current CRB disclosure which clearly states they are employed by this service. Records indicated that 30 of the care staff have completed their NVQ level 2 training or equivalent. Standard 28 of the National Minimum Standards for Older People stipulates that 50 of care staff must have NVQ level 2 or equivalent. A requirement relating to NVQ training has been issued in the relevant section of this report. Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 16 From examination of staffing records, interviewing the manager and staff the inspector identified gaps in training, including health and safety training for some staff at the home. Gaps in staff training would be clearer to identify if all staff had an individual training profile, which indicated the training requirements for staff including mandatory training. The inspector also recommended that the manager develop a training programme to highlight training needs for all staff. Staff interviewed were positive about the training offered by the home and the manager was clearly keen to ensure all staff have completed the training required. Two requirements relating to staff training have been made in the relevant section of this report. Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 17 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): 31, 33, 35 and 38 Quality in this outcome area is adequate. This judgement has been made using available evidence including a visit to this service. Service users, relatives and staff were very positive regarding the new manager of the home. More work needs to be undertaken by the registered manager and provider to monitor quality assurance at the home to fully meet this standard. Service users’ financial interests are safeguarded by satisfactory policies and procedures. Better systems must be developed to monitor health and safety compliance at the home with particular emphasis being placed on fire safety. EVIDENCE: The new manager is a qualified RMN and is undertaking the Registered Managers Award in September 2006. Comments received from relatives, staff and service users were very positive regarding the new manager of the home. Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 18 It was clear that the manager has taken the time to understand the needs of all the service users and how these needs are to be met. Although some quality assurance systems are in place further work needs to be carried out in order to ascertain the views of service users and their representatives regarding how the home is meeting their needs. The manager must develop a quality assurance system that meets all of the requirements of Standard 33 of the National Minimum Standards for Older People. It was also noted that service user meetings were not being recorded. Two requirements relating to these issues have been made in the relevant section of this report. The manager was able to describe the home’s policy and procedures in relation to service user’s finances. She explained that one service user manages her own finances and all other service users’ finances are managed by their next of kin. The manager informed the inspector that all minor purchases would be paid by the home and that she would be invoicing relatives every six months to reclaim these expenses. Satisfactory receipts in relation to service users’ minor expenses were seen. Service users that the inspector spoke with said they were happy with the way the home dealt with their finances. Fire door guards have been fitted to all service users’ bedroom doors where they want to keep the door open at night. As these fire door guards are battery operated the manager must keep a record of weekly checks to ensure the batteries are still functioning. Although records were seen, it was not clear whether these were records of the door alarm checks or fire call point checks. A requirement relating to this has been issued in the relevant section of this report. Other records in relation to fire safety were examined. There was no evidence in the fire safety files that night staff are receiving fire drill training every three months. Nor did the records indicate when fire alarm and emergency lighting were last serviced. The fire procedures require further attention by the registered manager and two immediate requirements relating to fire safety were issued on the day of the inspection. The manager assured the inspector that the fire safety issues would be dealt with as a matter of urgency. Satisfactory records were seen in relation to gas safety, electrical installation and PAT testing. A requirement relating to mandatory training for all staff including health and safety training has been issued under standard 30 within this report. Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 19 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 X 3 X X N/A HEALTH AND PERSONAL CARE Standard No Score 7 2 8 3 9 2 10 3 11 X DAILY LIFE AND SOCIAL ACTIVITIES Standard No Score 12 3 13 3 14 3 15 3 COMPLAINTS AND PROTECTION Standard No Score 16 3 17 X 18 3 3 X X X X X X 3 STAFFING Standard No Score 27 3 28 2 29 2 30 2 MANAGEMENT AND ADMINISTRATION Standard No 31 32 33 34 35 36 37 38 Score 3 X 2 X 3 X X 2 Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 20 Are there any outstanding requirements from the last inspection? N/A 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 OP38 Regulation 23(4) Requirement The registered manager must ensure that night staff undertake fire drills every three months. This was an immediate requirement issued on the day of the inspection. The registered manager must review fire procedures and policies in relation to the testing and maintenance of fire equipment as well as the emergency fire evacuation plan. This was an immediate requirement issued on the day of the inspection. The registered manager must ensure that care plans are developed to incorporate all the identified needs of service users, including social and emotional needs, and that these plans give clear information to staff on how these needs are to be met. The registered manager must ensure that a list of all staff able to administer medication be attached to the front of the DS0000066206.V304261.R01.S.doc Timescale for action 25/08/06 2. OP38 23(4) 08/09/06 3. OP7 15(1) 01/12/06 4. OP9 13(2) 01/11/06 Friary Lodge Version 5.2 Page 21 5. OP9 13(2) 6. OP28 18(1) c 7. OP29 19 (1) b 8. OP30 18(1) c 9. OP30 18(1) c 10. OP33 24(3) 11. OP33 24(3) 12. OP38 23(4) medication records which gives a sample of their signature as well as the date of their medication training. The registered manager must ensure that a photograph of each service user is attached to their corresponding medication chart. The registered manager must ensure that 50 of staff have completed NVQ level 2 training or equivalent. The registered manager must ensure that that all staff employed by Friary Lodge have a current CRB disclosure, which clearly states they are employed by this service. The registered manager must ensure that a training and development plan is developed for all staff at the home and is available for inspection. The registered manager must ensure that all staff receive the mandatory training, including health and safety training, required for working at the care home. The registered manager must ensure that effective quality assurance and quality monitoring systems, based on seeking the views of service users are in place covering the elements of Standard 33 of the National Minimum Standards for Older People. The registered manager must ensure that all service users’ meetings are recorded and include action taken by the management of the home as a result of service user’s comments. The registered manager must ensure that records are DS0000066206.V304261.R01.S.doc 01/11/06 01/02/07 01/12/06 01/12/06 01/12/06 01/12/06 01/11/06 14/09/06 Page 22 Friary Lodge Version 5.2 maintained of both the weekly testing of fire door guards and weekly fire call point tests. 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. 2. Refer to Standard OP1 OP30 Good Practice Recommendations The registered manager should review the homes statement of purpose and service user guide with regard to equality and diversity issues. The manager should develop a training overview for all staff at the home to better highlight training needs. Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 23 Commission for Social Care Inspection Southgate Area Office Solar House, 1st Floor 282 Chase Road Southgate London N14 6HA 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 Friary Lodge DS0000066206.V304261.R01.S.doc Version 5.2 Page 24 - 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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