Inspection on 14/02/06 for Gardenia House

This inspection was carried out on 14th February 2006.

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

Gardenia House 19/06/06

Gardenia House 09/09/05

Gardenia House 10/01/05

Gardenia House 07/09/04

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

CARE HOMES FOR OLDER PEOPLE Gardenia House 19 Pilgrims Court Farnol Road Dartford Kent DA1 5LZ Lead Inspector Wendy Jones Announced Inspection 14TH February 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 Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 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. Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 Page 3 SERVICE INFORMATION Name of service Gardenia House Address 19 Pilgrims Court Farnol Road Dartford Kent DA1 5LZ 01322 290837 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) Heritage Care Limited Vacant Care Home 25 Category(ies) of Old age, not falling within any other category registration, with number (23), Physical disability (1), Physical disability of places over 65 years of age (1) Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 Page 4 SERVICE INFORMATION Conditions of registration: 1. 2. Care for people with physical disabilities is restricted to one resident whose date of birth is 11/06/1936. Care for 1 older person with physical disabilities is restricted to a person whose d.o.b. is 21/06/1934. 9th September 2005 Date of last inspection Brief Description of the Service: Gardenia House is owned by English Churches and managed by Heritage Care Limited. It provides residential care for up to 25 people over the age of 65. All bedrooms are single and have en-suite facilities some have en-suite showers. Bedrooms are situated over three levels, which are accessed by a shaft lift. The home is situated on the outskirts of Dartford, relatively close to bus and train services and local amenities. There is a small, open, garden area to the rear, an enclosed garden area to the side and limited parking facilities at the front of the home. Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. This was an announced inspection carried out by Wendy Jones, Regulatory Inspector on Tuesday 14 February 2006 between 9:45am and 3:30pm. Judgements are based on conversations with residents, the manager and staff; reading of care plans and records; comments received prior to the inspection from resident, their relatives/visitors, GPs and other healthcare and social care professionals; and a tour of the home. What the service does well: What has improved since the last inspection? What they could do better: Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 Page 6 There is now a statement of purpose/service user guide available for all residents and prospective residents. However, more detail of how to make a complaint and the procedure followed should be included so that prospective residents know what to expect. Also these documents state that there is a no smoking policy in the home. Some residents smoke at designated times in a corner of the dining room, which contradicted this statement. The manager explained that this arrangement is only for residents who smoke and were living in the home before the smoking policy was implemented. It is recommended that the statement of purpose/service user guide is amended to make this clear to prospective residents. The complaints procedure must be updated to include details of how to contact the Commission. Care plans must be developed further and set out in detail the action staff must to take to meet residents’ health, personal and social care needs. Details of when healthcare professionals are asked to visit and the outcomes were not seen. The manager stated that this information is recorded in daily records. Details of visits by or to healthcare professionals e.g. district nurse, dentist, optician, chiropodist and outcomes must be kept to show that residents have access to these services when needed. Basic risk assessments that ensure the general safety of residents have been carried out. However, more detailed assessments, covering manual handling and areas of the home or grounds that present a risk of falling to individual residents would improve on these and must be carried out. Residents have a choice of meals. Improvements have been made to menus but these still need some further development to ensure a balanced and nutritious diet is available for residents. The manager explained that the cook is to attend training in nutrition to help with this. A special valentine’s meal was available for residents that day. Jars of jam etc., should be dated when they are opened so that they can be discarded when out of date. Not all bathroom doors are clearly marked so that residents are aware they are bathrooms. Signs should be fitted to all bathroom doors. The manager has registered on the Registered Managers’ Award and should aim to complete this within two years of the date he was employed. Records of induction need to be fully completed with signatures of the trainer and inductee and dates to show that all new staff have received appropriate training. Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 Page 7 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. Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 Page 8 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 Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 Page 9 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, 3, 4, and 5 Prospective residents and their relatives have suitable pre-admission written information and the opportunity to visit the home to decide whether their needs can be met. However, fuller details of the home’s complaints procedure and further clarification of the smoking policy would give them a fuller picture. EVIDENCE: There is now a statement of purpose/service user guide available for all residents and prospective residents. However, more detail of how to make a complaint and the procedure that will be followed should be included so that prospective residents know what to expect. Also these documents state that there is a no smoking policy in the home, but some residents smoke at designated times in a corner of the dining room, which contradicted this statement. The manager explained that this arrangement is only for residents who smoke and were living in the home before the smoking policy was implemented. It is recommended that the statement of purpose/service user guide is amended to make this clear to prospective residents. Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 Page 10 The manager confirmed that prospective residents and their relatives are encouraged to visit the home before making a decision. There is also a month trial period on both sides. Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 Page 11 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 Residents’ health, personal and social care needs are met and they are treated with respect. However, some risks of falling could be missed, as risk assessments are basic and not detailed enough for individual residents. Residents can be confident their wishes at the time of their death will be carried out and that they and their family will be treated sensitively and respectfully. EVIDENCE: Care plans seen contained basic information about residents’ personal and health care needs. Care plans contained a form for recording details of the personal care residents have received. One form recorded that the resident had been offered a bath on 30 October 2005 and 21 January 2006, which suggested that this resident had not had a bath for three months. The form also included a column for recording residents’ weight but this had not been completed. The Manager was confident that the resident had been bathed regularly but that this had not been recorded. He also stated that he intends to introduce weighing of residents on a monthly basis so that their weight can be monitored. Care plans must be developed further and set out in detail the action staff must take to meet residents’ health, personal and social care needs. Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 Page 12 Details of when doctors visit residents was seen in care plans. However, details of when other healthcare professionals are asked to visit and the outcomes were not seen. The manager stated that this information is recorded in daily records. Details of visits by or to other healthcare professionals e.g. district nurse, dentist, optician, chiropodist and outcomes must be kept to show that residents have access to these services when needed. Basic risk assessments that ensure the general safety of residents have been carried out. However, more detailed assessments, covering manual handling and areas of the home or grounds that present a risk of falling to individual residents would improve on these and must be carried out. The manager said that senior staff are to attend risk assessment training on 20 February 2006, which will give them the skills and knowledge to carry out more detailed assessments. Residents said that all their needs are being met and they are very happy with the help and support they get. They said “staff are very good” and they feel “very happy and comfortable”. Staff clearly got on well with residents and treated them with respect. Medication was stored appropriately and medication administration records seen had been accurately recorded. Risk assessments that had been carried out for residents who self medicate were also kept with these records. Controlled drugs records matched medication stored in the controlled drugs cupboard. Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 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 and 15 Residents enjoy a range of cultural, social and religious activities and have regular contact with their family and friends. Residents have a choice of meals, which are taken in pleasant surroundings. However, they would benefit from a more nutritionally balanced menu. EVIDENCE: A range of activities is available for residents to take part in including 40’s and 50’s karaoke, music, books, videos, bingo word games and outings. Details of the activities planned are displayed around the home. The activities coordinator is keen to develop these even further and said they intended to put together a committee, which will include residents, to plan activities and outings. Residents making their way to the lounge said that they were going to the coffee morning and were looking forward to the Valentine’s bingo that afternoon. Residents are able to use all communal areas. Some were seen sitting in the lounge and dining room. One resident was in their room and said they enjoyed watching DVDs and looking out of the window. They said that they can join in the activities whenever they want and enjoy the coffee mornings. They also talked of other activities provided such as bingo and going to shows. Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 Page 14 Residents have a choice of meals. Improvements have been made to menus but these still need some further development to ensure a balanced and nutritious diet is available for residents. The manager explained that the cook is to attend training in nutrition to help with this. A special valentine’s meal was available for residents that day. Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 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): 16 and 18 Residents are safeguarded from abuse and can be confident that their complaints are taken seriously and acted upon. However, they would benefit from having a personal copy of the full complaints procedure in their service user guide that includes details of how to contact the Commission. EVIDENCE: There have been no complaints since the last inspection. The complaints procedure does not include details of how a complainant can contact the Commission. The home’s service user guide does not currently contain full details of the complaints procedure and does not inform residents about the process and what to expect. The complaints procedure must be updated to include details of how to contact the Commission and a full copy given to residents. Linking them with the multi agency protocols would further enhance the home’s adult protection procedures. Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 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 Residents live in a clean, pleasant, safe, comfortable and well-maintained environment that meets their needs. EVIDENCE: The home is situated on the outskirts of Dartford. It has an entrance lobby leading into the main entrance hall with a lift to bedrooms on the first and second floors. Residents can use grab rails and other aids that have been provided around the home. All bedrooms are single with en suite facilities and some also have a shower. There are bathrooms with bath hoists on each floor. Two of these bathrooms had no sign on the door. These doors should be clearly marked so that residents are aware they are bathrooms. There is a comfortably furnished lounge on the first floor that also contains a dining table and chairs. The manager explained that he hopes to create a small kitchenette area with a microwave and kettle in the corner of this room. The dining room is on the ground floor with two fire doors leading to gardens Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 Page 17 to the back and side of the home. The kitchen leads from this room. A sign is displayed on the wall next to the fire exit to the rear garden giving times that residents can smoke in this area. Discussion took place about the appropriateness of having a designated smoking area in the dining room when residents have to eat in there. It was suggested that alternative arrangements for smoking are looked at. There are limited car parking spaces to the front of the house. The garden area to the side is surrounded by fencing and clearly belongs to the home. However, at the rear of the property the boundary for the home is not clear. There is a small patio area directly outside the fire door leading from the dining room. However, a path leads to a grassed area behind the patio that is to the rear of private houses opposite. A path to the left of the building leads to a side door access to the Baptist church. The manager advised that Heritage Care is currently looking at confirming and identifying the boundaries of the home. Residents’ rooms were comfortably furnished and contained the residents’ own furniture and effects. Despite it being a cold day the home was warm and residents said they were comfortable. Everywhere was clean and there were no offensive odours. All cleaning materials are now kept in a locked cupboard and tabards are available to put on when going into the kitchen. Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 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 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 - 30 The home’s recruitment process ensures that residents are protected and an appropriate number of skilled and competent staff are on duty at all times. EVIDENCE: There were two carers and a senior carer on duty to look after 23 residents. Staff were able to carry out their duties unhurriedly and efficiently and had time to speak with residents. A cook, the activities co-ordinator and the manager were also on duty. A staff list and duty rosters seen showed that an appropriate number of staff are on duty and residents’ needs are met at all times. Currently the manager is not included on these rosters. It was agreed that details of when he is on duty be included. There is currently a vacancy for a night senior carer. The manager explained that vacancies are advertised centrally and he was now waiting for the applications to be sent to him to shortlist for interview. The manager explained that currently there were two full time carers on long term sick and agency staff were being used to cover their shifts. Staff files seen contained all the information required including CRB checks and two references. Currently the home employs 15 carers. Five of these (30 per cent) have achieved at least NVQ 2 in care with two more due to complete soon. A Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 Page 19 further three members of staff have recently started the course. In addition three members of staff are due to start NVQ 3 in care. The induction and core training provided is assessed and reviewed by the senior carers and updates and further training are provided when needed. Induction records seen had not been signed off to confirm that staff had completed the induction programme or that their competency and understanding had been assessed. The manager was confident that new staff had completed the courses and had been assessed. Senior staff should ensure that records of induction are fully completed with signatures of the trainer and inductee and dates. Training records and certificates seen in staff files showed that staff have received training in manual handling, first aid, fire safety, food hygiene and medication over the last year. Training planned included manual handling refresher, adult protection, risk assessment, and customer care. Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 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 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, 32, 33, 35, 36 and 38 Residents benefit from living in a home which is well managed, safeguards their best interests and promotes and protects their health, safety and welfare. EVIDENCE: The manager has successfully applied to be the registered manager of the home. He has a number of years experience and is due to start the Registered Manager’s Award shortly. The manager should complete the Registered Managers’ Award within two years of the date of his employment. There is a calm and pleasant atmosphere in the home and residents spoken with were happy and contented. A large number of comment cards were received prior to the inspection from residents and their relatives or visitors who visit the home. The majority of comments were complimentary. Residents stated that they like living there, feel well cared for, are treated well and feel safe. Relatives or visitors said they can visit in private, are kept informed of important matters, are consulted and all are satisfied with the Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 Page 21 overall care provided. Additional comments included “first class”, “very well cared for”, and “staff go out of their way to make sure … is ok”. Small amounts of cash are kept for some residents in a locked safe in the home. Individual records are kept and those sampled tallied with receipts. Details were also seen of monthly audits of these records that had been carried out by the manager. Senior carers monitor and carry out formal recorded supervision of care staff. Records seen showed that care practice, training and development needs are discussed with staff. Supervision is usually carried out two monthly. Training records showed that staff receive regular updates on manual handling to avoid injury to residents or themselves and regular fire training is provided. The kitchen and dry store were clean. However, it was not possible to tell how long jars of jam etc., in the fridge had been open. The date when these are opened should be recorded so that they can be discarded when they are out of date. The home uses the company’s own accident book. Although separate copies of accident reports are removed from the book and stored securely and confidentially for each resident a copy of each report remains in the book. This appears to breach data protection regulations and the manager is to discuss this with the company. Pre-inspection information received and records sampled showed that all maintenance contracts and checks had been carried out and residents live in a safe and well maintained home. Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 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. 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 2 x 3 3 3 x HEALTH AND PERSONAL CARE Standard No Score 7 2 8 2 9 3 10 3 11 x DAILY LIFE AND SOCIAL ACTIVITIES Standard No Score 12 3 13 3 14 15 2 3 2 3 3 3 3 3 STAFFING Standard No Score 27 3 28 3 29 3 30 2 MANAGEMENT AND ADMINISTRATION Standard No 31 32 33 34 35 36 37 38 Score 3 2 COMPLAINTS AND PROTECTION Standard No Score 16 2 17 x 18 3 2 3 3 X 3 3 X 2 Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 Page 23 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 Requirement Timescale for action 31/05/06 2. OP8 12 3. OP15 16 4. OP16 22(5) and (7)(a) The registered person must prepare a written care plan as to how residents’ needs in respect of their health and welfare are met. The current care plans must be further developed to include actions staff must take to meet identified needs. The registered person must 31/05/06 promote and make proper provision for the health and welfare of residents and appropriate actions must be recorded in care plans. The registered person must 31/03/06 provide food which is varied and properly prepared and available at such time as may reasonably be required by residents. The proposed addition of a kitchenette in the 1st floor lounge area is likely to address this requirement in part. This requirement is continued from the previous inspection on 9 September 2005 A written copy of the complaints 31/05/06 procedure that includes the name, address and telephone DS0000023943.V274810.R01.S.doc Version 5.1 Gardenia House Page 24 5. OP19 23 number of the Commission must be supplied to all residents The premises must suitable for 31/05/06 the purpose of achieving the aims and objectives set out in the statement of purpose. The issues agreed with the manager as necessary are: • the availability of an inhouse person and the preparation of a maintenance schedule • the identification of the homes perimeters and subsequent maintenance of these. This requirement is continued from the previous inspection on 9 September 2005 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. 3. 4. 5. Refer to Standard OP1 OP21 OP30 OP31.2 OP38.2 Good Practice Recommendations The statement of purpose/service user guide should include fuller details of the complaints procedure and details of how to contact the Commission. All bathrooms doors should be clearly marked so that residents are aware they are bathrooms. Records of induction should be fully completed with signatures of the trainer and inductee and dates. The manager should complete the Registered Managers’ Award within two years of the date of his employment. Jars of jam etc., should be dated when they are opened to ensure they are discarded when out of date. Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 Page 25 Commission for Social Care Inspection Maidstone Local Office The Oast Hermitage Court Hermitage Lane Maidstone ME16 9NT 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 Gardenia House DS0000023943.V274810.R01.S.doc Version 5.1 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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