Inspection on 23/01/06 for Green Haven

This inspection was carried out on 23rd January 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

Green Haven 25/06/07

Green Haven 31/08/06

Green Haven 18/07/05

Green Haven 11/02/05

Green Haven 26/08/04

Green Haven 19/01/04

Green Haven 26/06/03

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

CARE HOMES FOR OLDER PEOPLE Green Haven 18 Montpelier Road Ealing London W5 2QP Lead Inspector Sarah Middleton Unannounced Inspection 23rd January 2006 10:10 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 Green Haven DS0000027707.V274239.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. Green Haven DS0000027707.V274239.R01.S.doc Version 5.1 Page 3 SERVICE INFORMATION Name of service Green Haven Address 18 Montpelier Road Ealing London W5 2QP 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) 0208 997 2142 0208 997 4235 Haven Green Housing Association Limited Ms Jacqueline Valerie Gordon Care Home 22 Category(ies) of Old age, not falling within any other category registration, with number (0), Physical disability over 65 years of age (0) of places Green Haven DS0000027707.V274239.R01.S.doc Version 5.1 Page 4 SERVICE INFORMATION Conditions of registration: Date of last inspection 18th July 2005 Brief Description of the Service: Green Haven provides a service for 22 older people. The home is well established and has been in operation since 1961. A voluntary committee manages Green Haven and meets every other month. The committees chairperson is the homes registered Responsible Individual. The home is supported by a group of volunteers known as the Friends of Green Haven. The majority of the service user group are frail elderly. However, the home aims to support service users in maintaining links with the community as far as is practical and in accordance with service users wishes. Green Haven is a large detached property in a quiet residential area of Ealing. The home has parking to the front of the building and a large garden and veranda at the back. It has three floors, with bedrooms on each floor. Those above the ground floor are accessed using the passenger lift. All bedrooms are single, one has en-suite facilities. The home has a large lounge and separate dining room. Smoking is only permitted in a part of the dining room. Green Haven DS0000027707.V274239.R01.S.doc Version 5.1 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. This was an unannounced inspection carried out as part of the regulatory process. A total of almost five hours, 10.10am-3pm, was spent on the inspection process. The Inspector carried out a tour of each floor of the home and inspected service user plans, staff files and maintenance records. Three service users, one visitor and two members of staff were spoken with as part of the inspection process. The home had met several of the previous requirements, however several new requirements were set following this inspection. This inspection report should be read in conjunction with the previous inspection report on the 18th July 2005. The Inspector would like to thank the staff, service users and visitor for assisting with this inspection. What the service does well: What has improved since the last inspection? The home had arranged training on the protection of vulnerable adults for all members of staff to ensure staff were aware of the issues surrounding this subject. The ground floor bathroom had been decorated and flooring been replaced. Temperatures were now being taken of all areas where service users have access, such as their individual washbasins. This close monitoring ensures the home is protecting the health and safety of service users. Green Haven DS0000027707.V274239.R01.S.doc Version 5.1 Page 6 Robust systems were now in place to monitor the quality of care offered and how the home operates. This is with the aim of identifying areas needing attention and improvement and areas that are currently working well. Service users or their representatives views had been obtained to ensure the Management had noted their views and opinions. 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. Green Haven DS0000027707.V274239.R01.S.doc Version 5.1 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 Green Haven DS0000027707.V274239.R01.S.doc Version 5.1 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): 3&5 Service users are assessed prior to admission to ensure the home can meet their needs. Prospective service users and their representatives are encouraged to visit the home in order to allow them to make an informed choice. EVIDENCE: The Inspector viewed pre-admission assessment documentation; this provided a picture of the service users needs, including any mental health or specific health issues. The Registered Manager usually assesses prospective service users in order to establish if the home can meet their needs. Where relevant the Registered Manager will aim to obtain a detailed assessment and risk assessment from the referrer in order to gather as much information about a prospective service user. Green Haven DS0000027707.V274239.R01.S.doc Version 5.1 Page 9 The service users who had recently been admitted had not been able to view the home, however their family members had visited. Where possible, prospective service users are encouraged to visit the home and spend time there to enable them to meet other service users and staff and to familiarise themselves with their potential new home. Green Haven DS0000027707.V274239.R01.S.doc Version 5.1 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 needs of service users, who had recently been admitted, had not been identified or documented in a care plan. Risk assessments had not been completed on recently admitted service users. Care plans and risk assessments must be completed in order for staff to know and understand how to support and care for individual service users appropriately. Service users health needs had been identified on one care plan viewed. Documentation is in place to record when service users have health appointments. Various health professionals visit the home in order to meet specific service users needs. There were several shortfalls identified regarding medication systems. Staff must sign when they have administered medication and not sign when they have failed to administer medication. Liquid medicine must have a date of opening on them and out of date medicines must not be used. These shortfalls could pose a risk to service users health and safety and must be addressed immediately. Service users were treated with respect and courtesy and their rights to privacy are up held within the home. Green Haven DS0000027707.V274239.R01.S.doc Version 5.1 Page 11 EVIDENCE: Samples of individual service users plans were viewed. The Inspector asked to examine care plans on recent admissions. Three service users had been admitted over the past three weeks, one only three days prior to the inspection. These files did not contain completed care plans or risk assessments. Discussions took place with the Registered Manager regarding the importance of completing care plans and risk assessments in order to identify needs and risks and to document ways to effectively support and care for the service users. The Inspector acknowledged the difficulty in identifying needs and risks on recent admissions, but these must be recorded and reviewed once a service user has settled into the home. A requirement was made for care plans and risk assessments to be completed on all service users living in the home. A care plan was viewed regarding a service user who had been living in the home for a while. This did indicate their health, personal and social needs and how these would be met. A risk assessment had also been completed and was up to date and reflected their current risks. In addition, photographs had not been taken of two service users recently admitted, this is a requirement. Documentation was viewed that is used to record when service users see a health professional, such as a Dentist, Optician or Chiropodist. Service users are weighed on a regular basis to enable staff to monitor any changes. All service users have a GP and staff support service users to attend any specialist health appointments. No service users living in the home had pressure sores. Samples of medication administration records were tracked and viewed. Gaps were noted where members of staff should have signed if they had administered medication, this is a re-stated requirement. Samples of liquid medicines were viewed; some of these had dates of opening written on them, whilst others did not, this is a re-stated requirement. One bottle of medicine that had been used and had been dated when opened, was out of date, a requirement was made that out of date stock must not be used. The Inspector noted that medication had been signed for regarding one service user on the morning of the inspection, but it was still in the doset box. A requirement was made that medicines must be administered as prescribed. Senior members of staff administer medication and receive ongoing refresher training on this subject. Discussions took place with the Registered Manager with regards to monitoring the errors that had been identified at both the previous inspection and this current inspection regarding medication systems. She acknowledged the need to consider developing a system to review medication on a regular basis in order to address these shortfalls. Green Haven DS0000027707.V274239.R01.S.doc Version 5.1 Page 12 Service users receive personal care in private. Staff confirmed they knock before entering service users bedrooms and that they respect service users dignity at all times, taking particular care during supporting service users with personal care. Service users are able to have their own private telephone in their bedrooms and can receive their own personal mail. Service users spoken with stated they always have their own clothes to wear. Staff were observed to address service users in a sensitive and courteous manner. Green Haven DS0000027707.V274239.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 & 15 Social activities are in place and aim to meet the service users interests and abilities. Visiting is encouraged for service users to maintain contact with family and friends. Meal provision within the home is of a high standard and offers service users nutritional meals and a well balanced diet that incorporates individual preferences and special diets. EVIDENCE: The home has an allocated member of staff who plans and reviews the activities on offer within the home. Staff were seen to stimulate and engage service users and a quiz was being run whilst the Inspector was at the home. Service users spoken with stated they could take part in any of the activities organised as they and when they choose to. Once a month a volunteer visits the home and cooks with service users. During summer months occasional outings are organised. The Registered Manager said that throughout the year entertainers are booked who offer various activities and entertainments for the service users. Green Haven DS0000027707.V274239.R01.S.doc Version 5.1 Page 14 The Inspector spoke with a visitor, who said they visited the home three times a week. They are able to see the service users in private or in the lounge and can visit whenever they choose to. Meals offered in the home incorporate special diets and individual preferences. The menus are planned on a four-week rolling menu and any alternatives are recorded each day. The kitchen assistant was seen to be providing an alternative for one of the service users. Fresh produce is used on a daily basis. The kitchen was clean and tidy at the time of the inspection. Fridge and hot food temperatures had been recorded daily and were within an appropriate range. Some food that had been opened or prepared had dates of opening/preparation written on them. However cheese that had been opened in two separate fridges had no dates of opening on them, this is a re-stated requirement. Service users spoken with were happy with the meals provided in the home and confirmed they were given choices regarding the meals they ate. Green Haven DS0000027707.V274239.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 & 18 The home has a clear complaints procedure and service users were confident their complaints would be listened to and acted on. Systems were in place for the protection of vulnerable adults. EVIDENCE: The home has a complaints procedure that is freely available and visible within the main reception of the home for service users and visitors to view. There have been no formal recorded complaints since 2004. The Registered Manager showed the Inspector the complaints form that would be used to record any formal complaints. Service users spoken with said that if they had any concerns they would take it to the Registered Manager. The home recently provided training in the protection of vulnerable adults, (POVA) for all staff through an external organisation visiting the home. Those staff asked said they would report any POVA concerns to the Management. There have been no POVA investigations regarding the home. Green Haven DS0000027707.V274239.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, 24, 25 & 26 The home is well maintained offering a pleasant and clean home for service users. Service users are able to have privacy with their personal possessions in their bedrooms. The home is adequately heated with appropriate lighting providing a safe and warm environment. EVIDENCE: A tour was carried out and a sample of rooms viewed. These were being satisfactorily maintained. A maintenance programme was viewed that outlined work to be carried out in the forthcoming year. Some work is still outstanding and will be addressed. The home employs a maintenance person who carries out the general work needing to be done throughout the home. The ground floor bathroom had been decorated and the flooring replaced. Green Haven DS0000027707.V274239.R01.S.doc Version 5.1 Page 17 Service users bedrooms are single rooms and offer service users the opportunity to bring their own personal possessions. Service users are able to hold a key to their bedrooms, as these rooms are lockable. Service users are able to have lockable storage in their bedrooms if they want this facility. The home was bright and offered a welcoming environment for service users and visitors. The maintenance person checks the water temperatures in all areas where service users have access on a regular basis. These were recorded within an appropriate range. Radiators are covered to protect service users. Emergency lighting is provided throughout the home and is tested and serviced on a regular basis. The home has a separate laundry room and staff carry out laundry tasks. Protective clothing is available to ensure the spread of infection is minimised. Domestic staff receive training and information on health and safety issues. The home was clean and free from malodours at the time of the inspection. Green Haven DS0000027707.V274239.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, 28, 29 & 30 Service users are supported by a sufficient number of staff who are suitably experienced and qualified to meet their individual needs. Service users benefit from staff studying NVQ courses and receiving ongoing training on relevant subjects. These training opportunities enable staff to reflect on their practice and to gain knowledge and information in relation to caring and supporting service users. The systems for the recruitment of staff are robust and safeguard service users. EVIDENCE: The staffing provision in the home is sufficient to meet the needs of the service users. Those staff asked stated that overall the numbers of staff working on each shift were adequate, although one staff member commented that some days can be busier than others. There are domestic staff employed in order to maintain the home to a high standard. Overall the staff team is stable with only one care assistant vacancy at present. The home encourages and supports staff to study NVQ courses and is currently meeting its target to ensure at least 50 of the staff team have either obtained or are in the process of studying for the NVQ qualification or equivalent course. Green Haven DS0000027707.V274239.R01.S.doc Version 5.1 Page 19 The staff employment files viewed contained details of the applicants completed application forms, a photograph of the applicant, Criminal Record Bureau checks, medical declaration and references. A copy of the terms and conditions of employment were also present in staff files. Samples of individual staff training files were viewed. The home is also in the process of keeping a clear record of all the courses and training staff attend to ensure staff attend refresher courses within the appropriate timescale. The Registered Manager showed the Inspector the current form used when going through an induction with new members of staff. This document is being reviewed and the Registered Manager hopes to implement a revised induction programme in the near future. Staff confirmed they attend mandatory training on subjects such as first aid, fire safety and manual handling. Staff stated they were happy with the level of training offered to them. Green Haven DS0000027707.V274239.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 & 38 The home is well managed and the Registered Manager has an approachable style of management. The staff team work well together in the interests of the service users. Systems are in place to review the quality of care offered within the home. This enables the home to consider areas needing improvement and attention and areas that work well for the benefit of the service users. The home has robust procedures in place to safeguard service users finances. The shortfalls in the servicing records could pose a risk to service users, staff and visitors. Appliances, such as the Gas Safety record must be up to date. In addition, all staff must take part in fire drills to ensure they know how to respond effectively in the event of a fire. Green Haven DS0000027707.V274239.R01.S.doc Version 5.1 Page 21 EVIDENCE: The Registered Manager has been in post for several years and has obtained the NVQ level 4 in management. They are due to begin studying to become a mentor in the home with the aim to offer additional support for staff. There are clear lines of accountability as the home also has a Deputy Manager and senior members of staff to support service users and other members of staff. Service users and staff commented that the Registered Manager is approachable and flexible. Staff felt they could seek advice and support from Management if they should need it. Systems are in place for reviewing the quality of care in the home. Monthly Regulation 26 visits take place and internal audits are carried out that look at various areas such as care plans and staffing. Furthermore service users are offered the option to complete questionnaires in relation to the home. The Inspector viewed a report that highlighted areas the home had examined and reviewed. This included any action the home needed to take for the benefit of the service users living in the home. Discussions took place with the Registered Manager regarding combining the views of service users and the Regulation 26 reports into the main report the home has produced in order to clearly demonstrate the different opinions and suggestions made. The Inspector met with members of staff who manage the service users finances. They have worked at the home for several years and have systems in place to monitor service users monies. Samples of service users monies were counted and were correct. Receipts are obtained and a record is kept of any transactions. Where possible service users manage their own finances with the support of their relatives or friends. Servicing records were viewed at random. The fire alarm, nurse call system, medic baths and emergency lighting had all been serviced and were up to date. The Portable Appliance Testing and the testing for legionella was up to date. The Gas Safety record was recently out of date. The Registered Manager stated she was aware of this and had been liaising with the new company due to provide this service within the next few days. A requirement was made that all servicing records must be up to date. Fire drills had taken place throughout the year but had not always clearly recorded the time of the drill and the members of staff who had attended. A requirement was made that all staff must be present for some of the fire drills held during the year and their names must be recorded along with the time of the drill. Green Haven DS0000027707.V274239.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 x x 3 x 3 N/A HEALTH AND PERSONAL CARE Standard No Score 7 1 8 3 9 1 10 3 11 x DAILY LIFE AND SOCIAL ACTIVITIES Standard No Score 12 3 13 3 14 x 15 2 COMPLAINTS AND PROTECTION Standard No Score 16 3 17 x 18 3 3 x x x x 3 3 3 STAFFING Standard No Score 27 3 28 3 29 3 30 3 MANAGEMENT AND ADMINISTRATION Standard No 31 32 33 34 35 36 37 38 Score 3 3 3 x 3 x x 2 Green Haven DS0000027707.V274239.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 Requirement Timescale for action 31/01/06 2. OP7 13(4)(c) & The Registered Person must 15 ensure that care plans & risk assessments are completed on all service users. (Previous timescale 1/8/05 not met with regards to risk assessments). Schedule The home must obtain a 3 photograph of each individual service user. 13(2) The Registered Person must ensure that the medication administration records are kept up to date and are recorded accurately. (Previous timescale 1/8/05 not met). The Registered Person must ensure that all liquid medicines have a date of opening on them. (Previous timescale 1/8/05 not met). The Registered Person must ensure that medicines used are not out of date. 31/01/06 3. OP9 22/01/06 4. OP9 13(2) 22/01/06 5. OP9 13(2) 22/01/06 Green Haven DS0000027707.V274239.R01.S.doc Version 5.1 Page 24 6. OP9 13(2) The Registered Person must ensure that medication is administered as prescribed. Food prepared or opened must have a date of opening/preparation written on it to ensure out of date food is not used. (Previous timescale 1/8/05 not met) The Gas Safety Record must be up to date. All staff must attend fire drills at regular intervals throughout the year. Times of drills and the names of staff attending the drill must be available for inspection. 22/01/06 7. OP15 16(2)(i) 22/01/06 8. 9. OP38 OP38 13(4)(a) (c) 23(4)(e) 31/01/06 31/01/06 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 Green Haven DS0000027707.V274239.R01.S.doc Version 5.1 Page 25 Commission for Social Care Inspection West London Area Office 58 Uxbridge Road Ealing London W5 2ST 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 Green Haven DS0000027707.V274239.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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