Inspection on 18/08/05 for Russell Hill (7)

This inspection was carried out on 18th August 2005.

CSCI has not published a star rating for this report, though using similar criteria we estimate that the report is Poor. 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

Russell Hill (7) 24/10/07

Russell Hill (7) 16/11/05

Russell Hill (7) 07/02/05

Russell Hill (7) 24/06/04

Similar services:

Ashlong House

Norbury Crescent (30)

Edenvale

Wadham Avenue

Chatsworth Care - Dawson House

Cowden Road, 52 - 54

Chatsworth Care - Tudor Lodge

Foxley Lane (121a)

Extracts from inspection reports are licensed from CQC, this page was updated on 09/07/2008.

CARE HOME ADULTS 18-65 Russell Hill (7) 7 Russell Hill Purley Surrey CR8 2JB Lead Inspector James Pitts Unannounced Inspection 18 August 2005 11:25am The Commission for Social Care Inspection aims to: • • • • Put the people who use social care first Improve services and stamp out bad practice Be an expert voice on social care Practise what we preach in our own organisation Reader Information Document Purpose Author Audience Further copies from Copyright Inspection Report CSCI General Public 0870 240 7535 (telephone order line) This report is copyright Commission for Social Care Inspection (CSCI) and may only be used in its entirety. Extracts may not be used or reproduced without the express permission of CSCI www.csci.org.uk Internet address This is a report of an inspection to assess whether services are meeting the needs of people who use them. The legal basis for conducting inspections is the Care Standards Act 2000 and the relevant National Minimum Standards for this establishment are those for Care Homes for Adults 18-65. They can be found at www.dh.gov.uk or obtained from The Stationary 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. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 3 SERVICE INFORMATION Name of service Russell Hill (7) Address 7 Russell Hill, Purley, Surrey, CR8 2JB Telephone number Fax number Email address Name of registered provider(s)/company (if applicable) Name of registered manager (if applicable) Type of registration No. of places registered (if applicable) 020 8763 4301 Caretech Community Services Limited Mr Neil Parker Care Home 11 Category(ies) of Learning Disability (11) registration, with number of places Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 4 SERVICE INFORMATION Conditions of registration: none Date of last inspection 7 February 2005 Brief Description of the Service: 7 Russell Hill is divided into three separate services, a one-bedded service, a two-bedded service and an eight bedded service. Three of the rooms in the eight-bedded service have a bedroom with en-suite facilities. Prospective service users in the eight-bedded service have large bedrooms with easy access to nearby bathroom and toilets. In the two-bedded service; service users have their own bedrooms but share a bathroom, living room and kitchen, in the one-bedded service the service user has the use of a private bathroom, bedroom, kitchen and living room. The homes purpose is to work specifically with people who have complex needs and require a high level of support in order to live their lives. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. This visit took place during daytime and there were five service users at home. The rest were either out at a day centre or doing other activities. Most of the service users who live here are not able to hold voice conversations but all can make at least some of their needs known in other ways. The Inspector spoke with one of the service users and observed what other people were doing in the house. The Inspector also spoke with the deputy manager and one of the staff team who was on duty. What the service does well: What has improved since the last inspection? Repairs in the house have shown some signs of improvement. The number of staff that are needed and the number that are provided is now clear. The home now has a full staff team in place. The number of staff that have either achieved the NVQ qualification, and have no started it, has improved to the point where the home should soon reach the 50 minimum that is required. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 6 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. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 7 DETAILS OF INSPECTOR FINDINGS CONTENTS Choice of Home (Standards 1–5) Individual Needs and Choices (Standards 6-10) Lifestyle (Standards 11-17) Personal and Healthcare Support (Standards 18-21) Concerns, Complaints and Protection (Standards 22-23) Environment (Standards 24-30) Staffing (Standards 31-36) Conduct and Management of the Home (Standards 37 – 43) Scoring of Standards Statutory Requirements Identified During the Inspection Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 8 Choice of Home The intended outcomes for Standards 1 – 5 are: 1. 2. 3. 4. 5. Prospective service users have the information they need to make an informed choice about where to live. Prospective users’ individual aspirations and needs are assessed. Prospective service users’ know that the home that they will choose will meet their needs and aspirations. Prospective service users have an opportunity to visit and to “test drive” the home. Each service user has an individual written contract or statement of terms and conditions with the home. The Commission consider Standard 2 the key standard to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 2 The service users can feel confident that the home will only care for people that the staff are trained and able to care for. The service users are told about how much it costs to live at the home and whenever this amount changes all of the people who need to know are told. EVIDENCE: The inspector looked at one recently admitted service user file at the time of the previous announced inspection and had found evidence of comprehensive referral information which was submitted by the Care Manager from the service users placing local authority. The inspector was also shown an assessment carried out under the home’s own referral and assessment protocols. There was sufficient information in place to show that the decision on this service user’s placement had been taken in light of suitable information about their care and support needs. As this home is meant to be a very longterm placement for the people who come to live here it will be very rare that new service users are admitted. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 9 Individual Needs and Choices The intended outcomes for Standards 6 – 10 are: 6. 7. 8. 9. 10. Service users know their assessed and changing needs and personal goals are reflected in their individual Plan. Service users make decisions about their lives with assistance as needed. Service users are consulted on, and participate, in all aspects of life in the home. Service users are supported to take risks as part of an independent lifestyle. Service users know that information about them is handled appropriately, and that their confidences are kept The Commission considers Standards 6, 7 and 9 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 6,7 & 9 The service users can feel confident that staff generally know what they need. Service users can also be assured that the staff will try their best to make sure that each person who lives at the home is allowed to live the sort of life that they choose. The only risk to this happening well is that staff do need to get better at making sure that they can show what happens whenever a service user behaves in a way that might hurt themselves or others. EVIDENCE: The inspector looked at three service users care plans, which are known as “ Individual Support Requirements “. These are written in a way that makes it look as though these really are about what the service user thinks as the words that are used are things like “how staff assist me with personal care” and “how staff treat me and my communication needs”. One thing that concerns the Inspector is that some of the service users are showing more signs of distress and are either hurting themselves or becoming angry and hitting out at other people. When things like this occur the staff write an incident report although it is unclear whether these are then leading to the proper response to why and how to support service users to be safe. The home Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 10 must write to the Commission and fully outline what happens if service users show signs of increasingly doing things that harm themselves or others. None of the service users could meaningfully sign their plan to agree to what is written in it, however, family members and care managers are closely involved with the home when these are written and when they are reviewed. The inspector had noted on a visit to the home last year that the kitchen door is kept locked, and on this visit the same practise was also again in evidence. There is a risk assessment in place, which explains why this needs to happen. Each service user has risk assessments completed in their personal plans that refer to the fact that service users may use the kitchen with the support of staff. The care plans also include risk assessments that tell staff and other people about anything that may harm a service user and anything that the person might do that might hurt themselves. Copies of risk assessments are kept in the service users file and cover a variety of situations from accessing community activities to learning skills and activities within the home. Risk assessments are reviewed very often. This is supposed to be done to make sure that they are still correct. However, given the concerns about some service users displaying more harmful behaviours it is not clear whether these fully explain what staff can do to lessen the risks to service users. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 11 Lifestyle The intended outcomes for Standards 11 - 17 are: 11. 12. 13. 14. 15. 16. 17. Service users have opportunities for personal development. Service users are able to take part in age, peer and culturally appropriate activities. Service users are part of the local community. Service users engage in appropriate leisure activities. Service users have appropriate personal, family and sexual relationships. Service users’ rights are respected and responsibilities recognised in their daily lives. Service users are offered a healthy diet and enjoy their meals and mealtimes. The Commission considers Standards 12, 13, 15, 16 and 17 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 11, 12, 13, 14, 15 & 16 Service users can feel confident that the staff of the home will provide opportunities for everyone to develop their personal and social skills. This includes active support for each person to participate in the community both in terms of the activities of daily life and leisure interests. The opportunity for each service user to develop and maintain personal and family relations is also offered and is actively supported by the staff team. EVIDENCE: The staff team encourage and help all of the service users to take part in a wide range of activities. Some service users attend day centres, college classes and community activities, as well as one service user who works at a local charity shop. When anyone is not doing one of these things the staff support service users to have a fulfilling week by providing opportunities for recreational activities and in-house activities. The home has a weekly schedule of tasks for each service user which also says how much each person would want to do and how they would want to do it. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 12 Service users are supported to participate in and use a wide range of community based facilities. These can be anything from regular shopping trips, whether for food for the home or personal shopping, to attendance at local clubs run by particular organisations. The home has two people carrier (type) vehicles that are regularly used although this does not prevent the use of public transport where circumstances and the needs of individual service users would allow. The home’s staff group encourage service users to maintain relationships with their family members and virtually all do have at least some family contact. For the one service user who has no family contact, there is still an independent advocate who can be contacted to act in their interests. There is an open visitors policy. Family and friends are invited to social events at the home as well as service user reviews. The home has a key worker system and it is part of the key worker role to keep family members informed of progress made, where appropriate. Visitors can be seen in the communal areas, of which the home has a range, or service users bedrooms if it is thought to be appropriate and safe to do so. The daily routines of the home are reasonably flexible. Staff were seen to interact with service users appropriately. Service users have the liberty to make their own choices about where they spend time in the home and whether they wished to be alone or in company. The home has all appropriate policies and practices on maintaining service users dignity and rights. The home has a keypad entry system to the front door and fire escape exits, the locks for which disengage automatically if the fire alarm is activated. All of the service users would be at risk if the left the home without being accompanied by at least one member of staff. The reasons for the entry and exit door locking system are fully documented and the appropriate measures are in place to secure the service users safety by using this. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 13 Personal and Healthcare Support The intended outcomes for Standards 18 - 21 are: 18. 19. 20. 21. Service users receive personal support in the way they prefer and require. Service users’ physical and emotional health needs are met. Service users retain, administer and control their own medication where appropriate, and are protected by the home’s policies and procedures for dealing with medicines. The ageing, illness and death of a service user are handled with respect and as the individual would wish. The Commission considers Standards 18, 19, and 20 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 18, 19, 20 & 21 Service users can feel confident that they will get the right support to take care of their personal and healthcare needs. Anyone who needs to take medicine regularly to help them stay well will get the proper support from staff to make sure that this happens. EVIDENCE: Russell Hill has a large staff team and this is required in order to provide the very high level of support that service users need. The methods of supporting each individual are clearly written down in a way that focuses on the unique preferences and personality of each service user. Each staff member is required by the home to sign a confirmation that they have read the individual plan and will put it into practise. Staff who spoke with the Inspector demonstrated a clear awareness of their responsibility to be sensitive and flexible in providing personal support. Service users make use of the range of community health services. Each service users health care needs are reflected in their care plan. A full medical profile is compiled which details the reason for prescription and any risks that might arise about the use of the medication that is prescribed. The outcome of all medical appointments is also written down. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 14 One service user suffers from insulin dependent diabetes. It is again evident that the local specialist diabetes community nurse has trained all senior staff to administer the required insulin injections that are given by means of an insulin pen. The Inspector noted that the insulin is kept in a locked refrigerator in the senior support workers office and that used needles are being stored properly in a sharps box prior to disposal. One service user at times requires the use of rectal diazepam when having a series of epileptic seizures. Staff are trained to administer this medication, although for newly appointed staff they are not permitted to do so until approved training is provided. Risk assessments indicate that none of the service users are able to take their medication without the staff supporting them. The home has a policy and procedure for handling medication. All staff members responsible for administering medication have been trained to do so. A monitored dosage system is used with all records being well and accurately kept. The home receives training and advice from their local chemist in regards to all medication. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 15 Concerns, Complaints and Protection The intended outcomes for Standards 22 – 23 are: 22. 23. Service users feel their views are listened to and acted on. Service users are protected from abuse, neglect and self-harm. The Commission considers Standards 22, and 23 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 23 The service users can feel confident that the staff team at the home know what to do if there are complaints or concerns about abuse. The home has clear guidance for staff about the procedures to be followed in either of these circumstances, although staff still need to be trained in the local authority’s own procedures so that they understand how these fit into the ones that the home uses. EVIDENCE: The inspector viewed the organisations complaints policy and the service users complaints procedure. The service users procedure is completed in widget form be the benefit of easy understanding. The complaints procedure is comprehensive and staff are clearly told how to record and complaints that are made. There have been three minor complaints that have been made by a neighbour, all of which were about noise in the garden during the day and none of which were particularly serious. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 16 The inspector required at the previous unannounced inspection that the registered manager and staff seek training on Croydon Councils Protection of Vulnerable Adult Policy. It was not possible to confirm whether this has occurred as only the manager has access to staff files and was away on holiday at the time of this visit. The requirement will stay in this report until it can be shown by the home that it has been met. The policy of the geographical authority in which the home is located, namely Croydon Councils Protection of Vulnerable Adult Policy, is available for the staff to see at the home. As a result of an inquiry that occurred last year under the protecting vulnerable adults procedures the managing organisation were advised by the Commission that at least one member of staff who has been dismissed from employment should referred to the POVA register (Protection of Vulnerable Adults Register) once this became active in July 2004. The Inspector has repeatedly asked the managing organisation whether this has occurred and has still not received a reply. although it is noted that retrospective notification was not required. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 17 Environment The intended outcomes for Standards 24 – 30 are: 24. 25. 26. 27. 28. 29. 30. Service users live in a homely, comfortable and safe environment. Service users’ bedrooms suit their needs and lifestyles. Service users’ bedrooms promote their independence. Service users’ toilets and bathrooms provide sufficient privacy and meet their individual needs. Shared spaces complement and supplement service users’ individual rooms. Service users have the specialist equipment they require to maximise their independence. The home is clean and hygienic. The Commission considers Standards 24, and 30 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 24 & 30 The service users can feel confident that they are living in a well maintained and clean home. EVIDENCE: One of the service users was kind enough to show the Inspector around their home. There are some small areas of redecoration that are again required in the hallways. At the time of the inspection the home was found to be in an otherwise good state of repair, accessible, suitable for the service users who live here and well furnished. The inspector saw at the inspection noted that one toilet seat in the eightbedded service was broken and needed replacing and that on toilet seat in the one-bedded service is missing. These have been replaced. The home has enough bathrooms and toilets for the service users to use. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 18 The house was found to be safe, comfortable, bright, cheerful, and free from offensive odours. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 19 Staffing The intended outcomes for Standards 31 – 36 are: 31. 32. 33. 34. 35. 36. Service users benefit from clarity of staff roles and responsibilities. Service users are supported by competent and qualified staff. Service users are supported by an effective staff team. Service users are supported and protected by the home’s recruitment policy and practices. Service users’ individual and joint needs are met by appropriately trained staff. Service users benefit from well supported and supervised staff. The Commission considers Standards 35 the key standard to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 33, 34, 35 & 36 Service users can feel confident that there will be enough staff on duty each day to meet their needs and that these staff are safe and well trained in how to support them. The home does make sure that day to day staff records are kept on site. It is still necessary to also show that staff supervision is getting better and that this is happening at least six times each year for each member of staff. EVIDENCE: The home has a large staff team, made up of a mixture of full and part time staff. The figures for staffing hours that is provided and needed is now less confusing. The deputy manager informed the Inspector that there is now a full staff team in post and that there is rarely a need to use bank or agency staff unless staff are off sick or on leave. Since the previous inspection the manager clarified with the Inspector the confusion that had arisen about the numbers of staffing hours that were needed and the number that the home actually uses. The home has a risk assessment regarding the sleep-in and waking night cover of the home, although rarely are sleep in staff required as here are three staff awake on duty each night. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 20 It was noted at the previous inspection that original staff CRB checks are not being kept at the home (Criminal Records Bureaux). The Commission has agreed that these may be kept at the company’s head office. It was also recommended that the managing organisation add a specific question to their standard reference request format that asks a referee if they have any reason to believe that an applicant is unsuitable to work with vulnerable adults. This has now been done and a copy was sent to the Inspector after the previous inspection visit. All staff undertake a six month foundation course that is linked to the learning disability award framework. A requirement for staff in passing their probationary employment period is that they complete this course. The home has 8 staff that are now qualified at NVQ 2 or above and five who are undertaking this qualification at present. The organisational policy is that all staff receive six to eight weekly supervision, however, evidence to show whether this has been achieved could not be seen as the manager was on leave and staff files were not accessible, This requirement will remain in this report until such time as it can be verified at a future visit. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 21 Conduct and Management of the Home The intended outcomes for Standards 37 – 43 are: 37. 38. 39. 40. 41. 42. 43. Service users benefit from a well run home. Service users benefit from the ethos, leadership and management approach of the home. Service users are confident their views underpin all self-monitoring, review and development by the home. Service users’ rights and best interests are safeguarded by the home’s policies and procedures. 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 are promoted and protected. Service users benefit from competent and accountable management of the service. The Commission considers Standards 39, and 42 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 42 The service users can feel confident that they are living in a home that is generally safe, although a couple of health and safety checks do still need to be put into place. EVIDENCE: The Following List of safety checks were examined: IEE: 30/09/04 Pat Test: 01/03/05 Gas Safety check: 17/11/04 Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 22 Legionellosis: (no written confirmation or certificate was available) Fire Alarm Warning System: 25/10/04 Fire Extinguishers: A copy of the check for Legionellosis must be copied to the Commission and this check must be carried out if it has not already been. The Inspector is concerned that there does not seem to be any checks carried out of the hot water to make sure that it is within safe temperatures. Checks must be carried out regularly to ensure that service users are not at risk of being scalded if they use the baths or showers. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 23 SCORING OF OUTCOMES This page summarises the assessment of the extent to which the National Minimum Standards for Care Homes for Adults 18-65 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 CONCERNS AND COMPLAINTS Standard No 1 2 3 4 5 Score N/A 3 N/A N/A N/A Standard No 22 23 ENVIRONMENT Score 3 2 INDIVIDUAL NEEDS AND CHOICES Standard No 6 7 8 9 10 LIFESTYLES Score 2 3 N/A 2 N/A Score Standard No 24 25 26 27 28 29 30 STAFFING Score 3 N/A N/A N/A N/A N/A 3 Standard No 11 12 13 14 15 16 17 3 3 3 3 3 x N/A Standard No 31 32 33 34 35 36 Score N/A N/A 3 3 3 2 CONDUCT AND MANAGEMENT OF THE HOME PERSONAL AND HEALTHCARE SUPPORT Standard No 18 19 20 21 Russell Hill (7) Score 3 3 3 3 Standard No 37 38 39 40 41 42 43 Score N/A N/A N/A N/A N/A 1 N/A G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 24 no Are there any outstanding requirements from the last inspection? STATUTORY REQUIREMENTS This section sets out the actions which must be taken so that the registered person/s meets the Care Standards Act 2000, Care Homes Regulations 2001 and the National Minimum Standards. The Registered Provider(s) must comply with the given timescales. No. 1. Standard 6 Regulation 15 (2) Requirement The home must write to the Commission and fully outline what happens if service users show signs of increasingly doing things that harm themselves or others. Risk assessments must show how the home is responding to the risks associated about some service users displaying more harmful behaviours. The home must ensure that the registered manager and staff seek training on Croydon Councils Protection of Vulnerable Adult Policy. The home must ensure that an improved frequency of staff supervision occurs that results in staff supervision to at least the minimum level that is required by regulation. The Legionellosis test certificate must be copied to the Commission and hot water temperature checks must also occur. Timescale for action 18/10/05 2. 9 13 (4) 18/10/05 3. 23 13 (6) with immediate effect with immediate effect 4. 36 18 (2) 5. 42 23 (2) (b) &(p) with immediate effect 6. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 25 RECOMMENDATIONS These recommendations relate to National Minimum Standards and are seen as good practice for the Registered Provider/s to consider carrying out. No. 1. Refer to Standard 23 Good Practice Recommendations The managing organisation are advised to inform the Commission in writing of the decision that was taken in regard to a referral to the POVA register of a former employee. Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 26 Commission for Social Care Inspection 8th Floor Grosvenor House 125 High Street Croydon CR0 9XP 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 Russell Hill (7) G53 S43125 russellhill7 V223802 180805 stage4.doc Version 1.40 Page 27 - 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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