Inspection on 25/07/06 for St Elmo Care Home

This inspection was carried out on 25th July 2006.

CSCI has not published a star rating for this report, though using similar criteria we estimate that the report is Good. The way we rate inspection reports is consistent for all houses, though please be aware that this may be different from an official CSCI judgement.

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

Other inspections for this house

St Elmo Care Home 13/02/08

St Elmo Care Home 25/10/05

St Elmo Care Home 17/05/04

Similar services:

St Vincents

Hamilton House

The Cotswold Home

Newbeech House

Newbeech House

Winton House

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

CARE HOMES FOR OLDER PEOPLE St Elmo Care Home Gorley Road Poulner Ringwood Hampshire BH24 1TH Lead Inspector Beverley Rand Unannounced Inspection 25th July 2006 10:00 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 St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 2 This is a report of an inspection to assess whether services are meeting the needs of people who use them. The legal basis for conducting inspections is the Care Standards Act 2000 and the relevant National Minimum Standards for this establishment are those for Care Homes for Older People. They can be found at www.dh.gov.uk or obtained from The Stationery Office (TSO) PO Box 29, St Crispins, Duke Street, Norwich, NR3 1GN. Tel: 0870 600 5522. Online ordering: www.tso.co.uk/bookshop This report is a public document. Extracts may not be used or reproduced without the prior permission of the Commission for Social Care Inspection. St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 3 SERVICE INFORMATION Name of service St Elmo Care Home Address Gorley Road Poulner Ringwood Hampshire BH24 1TH 01425 472922 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) St Elmo Care Home Ltd Mrs Marese Carol Mary Pitman Care Home 23 Category(ies) of Dementia - over 65 years of age (23), Old age, registration, with number not falling within any other category (23) of places St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 4 SERVICE INFORMATION Conditions of registration: Date of last inspection 25th October 2005 Brief Description of the Service: St Elmo is set in a residential area close to local amenities and about half a mile from Ringwood town centre. It provides residential care for up to 23 older people, many of whom have dementia. The home is on ground and first floors and there is a stairlift between these. There are a variety of aids and adaptations to allow residents to move about more independently. Seventeen of the bedrooms are single and three are doubles. Five of the single rooms have an en suite toilet. There are two communal toilets on the ground floor and a bathroom on the first floor. There is a garden to the side and front of the property. The fees vary between £457 for a shared room and £496 for a large ensuite room. This information was supplied on the day of the inspection. St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. The inspection was unannounced and the inspector spoke with three residents, two visitors, three staff, the deputy manager and the registered manager. The manager showed the inspector around the home and explained about the new extension under construction. Records such as care plans and staff training files were looked at. What the service does well: What has improved since the last inspection? What they could do better: Records regarding the amount of medication kept in the home need to be more detailed, out of date prescribed liquids must be disposed of and medication kept in the fridge must be securely kept. The laundry was in need of a thorough clean and this must be done to ensure a clean and cleanable St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 6 environment to reduce the risk of cross infection. A staff member had been allowed to work in the home before the appropriate recruitment checks were in place. Some bedroom doors were wedged open with furniture or cushions, and meant that they would not close if there was a fire. Not all staff have had updated fire safety training regarding what to do in the event of a fire. 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. St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 7 DETAILS OF INSPECTOR FINDINGS CONTENTS Choice of Home (Standards 1–6) Health and Personal Care (Standards 7-11) Daily Life and Social Activities (Standards 12-15) Complaints and Protection (Standards 16-18) Environment (Standards 19-26) Staffing (Standards 27-30) Management and Administration (Standards 31-38) Scoring of Outcomes Statutory Requirements Identified During the Inspection St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 8 Choice of Home The intended outcomes for Standards 1 – 6 are: 1. 2. 3. 4. 5. 6. Prospective service users have the information they need to make an informed choice about where to live. Each service user has a written contract/ statement of terms and conditions with the home. No service user moves into the home without having had his/her needs assessed and been assured that these will be met. Service users and their representatives know that the home they enter will meet their needs. Prospective service users and their relatives and friends have an opportunity to visit and assess the quality, facilities and suitability of the home. Service users assessed and referred solely for intermediate care are helped to maximise their independence and return home. The Commission considers Standards 3 and 6 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 3. Standard 6 does not apply to the home. Quality in this outcome area is good. This judgement has been made using available evidence including a visit to the service. The home ensures that residents move in after their needs have been assessed. EVIDENCE: The manager or deputy manager visit a prospective resident at their home or where they are currently and complete an assessment of their needs. They also get care management assessments when possible. Prospective residents and their families are also welcome to look around the home before they decide to move in. St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 9 Health and Personal Care The intended outcomes for Standards 7 – 11 are: 7. 8. 9. 10. 11. The service user’s health, personal and social care needs are set out in an individual plan of care. Service users’ health care needs are fully met. Service users, where appropriate, are responsible for their own medication, and are protected by the home’s policies and procedures for dealing with medicines. Service users feel they are treated with respect and their right to privacy is upheld. Service users are assured that at the time of their death, staff will treat them and their family with care, sensitivity and respect. The Commission considers Standards 7, 8, 9 and 10 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 7, 8, 9 & 10 Quality in this outcome area is good. This judgement has been made using available evidence including a visit to the service. The home ensures that each resident has a care plan, has access to healthcare professionals and are treated with respect. Residents may be better protected by more robust medication recording procedures. EVIDENCE: The inspector looked at three care plans which included information such as assessment, needs, social history and contact details. Care plans showed basic guidelines regarding how individual needs should be met, but during discussion with three staff, it was evident that they were very aware of individual needs and were meeting them in a consistent way. Staff were also aware of some residents’ complex needs at night, even though they did not work nights. Care plans and other records showed that healthcare professionals such as doctors visited the home where necessary. The chiropodist visits regularly, and the home can access a dentist and optician. Staff only administer medication if they are trained and the manager said five staff have taken a distance learning, three month college course, ‘Medication St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 10 Awareness’. The recording sheet for administering medication for each resident is labelled with their name, room number and photograph which is seen as good practice. Medication is currently stored in three different places and the manager said there were plans to change this once the new building had been completed. The pharmacist sorts the majority of medication into blister packs, but new or ‘as required’ medication is kept separately. The home does not have a clear audit trail for medication coming into the home. The inspector found that for one resident, there appeared to be not enough of a particular tablet, but after others had been looked for it was found that they were surplus and should have been returned. One drug was being kept separately as a controlled drug, but the amount into the home had not been recorded. The management thought there should be a certain number, but there were more than expected, which means that the home would not know if some had gone missing. The home must be able to account for all medication on the premises, particularly those which may be misused. A bottle of opened vitamin medication was found to be out of date by two months. An unlocked container was kept in the fridge which contained prescription eye drops – all medication must be securely kept. Three residents and two visitors who spoke with the inspector said that staff were, ‘very kind’, ‘caring’ and ‘nice’. Staff gave examples as to how they respected residents’ privacy whilst undertaking personal care, such as covering them with a towel when using the toilet or a blanket when using the hoist and using a screen in shared rooms. Staff talked about residents in a respectful way, showing understanding of their characters and personalities. Some residents have their own telephone line in their bedrooms so they can have calls in private. Care plans showed residents’ preferred names, which staff used. St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 11 Daily Life and Social Activities The intended outcomes for Standards 12 - 15 are: 12. 13. 14. 15. Service users find the lifestyle experienced in the home matches their expectations and preferences, and satisfies their social, cultural, religious and recreational interests and needs. Service users maintain contact with family/ friends/ representatives and the local community as they wish. Service users are helped to exercise choice and control over their lives. Service users receive a wholesome appealing balanced diet in pleasing surroundings at times convenient to them. The Commission considers all of the above key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 12, 13, 14 & 15 Quality in this outcome area is good. This judgement has been made using available evidence including a visit to the service. The home ensures that residents enjoy meals and activities, can personalise their rooms and can welcome visitors. EVIDENCE: Residents can get up and go to bed when they choose and this was evidenced by talking to a resident, and hearing a conversation between staff and a tradesperson who was due to visit. A particular care worker facilitates activities twice a week. Activities include a singer visiting twice a month, an art therapist twice a month, an aromatherapist who offers hand massages once a month and movement to music. Other activities include a ‘pat dog’, bingo, occasional trips out for those who are able to participate, and reminiscence, (such as looking at household items of yesteryear). One resident told the inspector that care staff would take her into the garden, or to the shops, or that she would spend time talking with another resident who she liked. Another resident did not generally participate in activities, but liked to spend a lot of time reading and watching television. A vicar also holds a monthly service. Visitors are welcome at any time and residents confirmed that staff made their visitors feel welcome and offered them drinks. One resident recently had a birthday and twenty family members came to the home and a party was held St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 12 in the garden. The two visitors also said they felt welcome, and one said they visited at different times, but that this was not a problem to staff. During a tour of the home, it was evident that bedrooms were personalised with residents’ own pieces of furniture, ornaments and photographs. Residents look after their own money using the facilities provided by the home. One resident who was walking through the home told the inspector he had enjoyed lunch. One resident described the food as, ‘adequate’ and said they always had a cooked breakfast. Another resident said they liked breakfast, had a lovely cup of tea when woken in the morning, had a lovely lunch and had a hot chocolate or Ovaltine before bed. They also said that staff would ask what they would like for supper, ask if they had had enough food, and would not mind if they could not eat all of the meal. A visitor said their relative enjoyed the food. Staff were aware of individual preferences, and gave examples regarding how they had noticed if residents were not eating particular food items, and what was done to ensure they enjoyed their food. Two people have pureed or mashed food and this varies according to their needs on a given day. A record is kept of what food is provided to individual residents. Fresh fruit was available and the manager said she had tried to include more fruit puddings on the menu. Biscuits and cake are provided with drinks during the day. The deputy manager told the inspector that the home was aware of the potential risks from the current heat wave, and that residents were provided with drinks ‘on tap’. Shopping is delivered on a weekly basis and food such as fruit and vegetables is bought from a supermarket twice a week. St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 13 Complaints and Protection The intended outcomes for Standards 16 - 18 are: 16. 17. 18. Service users and their relatives and friends are confident that their complaints will be listened to, taken seriously and acted upon. Service users’ legal rights are protected. Service users are protected from abuse. The Commission considers Standards 16 and 18 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 16 & 18 Quality in this outcome area is good. This judgement has been made using available evidence including a visit to the service. Residents and their representatives feel able to complain and training has been given to staff to ensure they know about different types of abuse. EVIDENCE: The home has a complaints procedure which includes timescales. A copy is displayed in the entrance hall and the visitors told the inspector they thought they had a copy. The manager said that residents would generally be unable to understand the procedure and so did not have an individual copy, but that relatives were given one. The inspector spoke with two visitors, one of whom had made a complaint and was happy with the outcome, and the other who said they felt able to complain if necessary. The home had not kept a written record of these complaints, seeing them as being resolved at a local level, but the manager agreed to keep a record, which is a legal requirement. Staff have received training in the protection of vulnerable adults in the last year and were clear that they would report any suspicions of abuse to the manager. However, staff, including senior staff, were not clear about the procedures which would then be followed or about the lead investigative role of the local authority adult services teams. St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 14 Environment The intended outcomes for Standards 19 – 26 are: 19. 20. 21. 22. 23. 24. 25. 26. Service users live in a safe, well-maintained environment. Service users have access to safe and comfortable indoor and outdoor communal facilities. Service users have sufficient and suitable lavatories and washing facilities. Service users have the specialist equipment they require to maximise their independence. Service users’ own rooms suit their needs. Service users live in safe, comfortable bedrooms with their own possessions around them. Service users live in safe, comfortable surroundings. The home is clean, pleasant and hygienic. The Commission considers Standards 19 and 26 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 19 & 26 Quality in this outcome area is good. This judgement has been made using available evidence including a visit to the service. The home is comfortable and clean but the laundry is in need of major cleaning. EVIDENCE: The home is currently being extended to include extra general rooms and an ensuite bedroom and the building work is likely to take a further three and a half months. A shaft lift is also going to be installed. Risk assessments are on going with regard to the changing environment. Due to the building work the home has storage problems, but this will be temporary. Although two or three bedrooms have been redecorated before new residents have moved in, there is a plan to refurbish the home with new furniture and carpets after the new building is completed. One resident who spoke with the inspector in this regard said they liked their room. The manager makes and paints photograph frames, which a photograph of the resident is put into, and this is hung on the door of their bedroom. This is seen as good practice as it helps people who are St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 15 confused to find their room independently. The home employs a gardener and the gardens were well tended, with a range of summer bedding. A visitor said the home was kept clean. Staff explained how they used protective gloves and aprons to reduce the risk of cross infection. The home has a contract for the disposal of clinical waste. However, the laundry is based in a garden shed and it was clear that it had not been cleaned for some time, which staff confirmed. An unknown liquid had leaked on the floor, (possibly from the machines), there were thick, dusty cobwebs around the walls and roof, the top of the washing machine was covered with washing powder and the worktop used to store individual clothes baskets was dirty. At the end of the inspection the manager said she had not been aware of the extent of the laundry’s condition, and had thought it was included on the cleaning schedules. Although the laundry will be relocated when the building work is finished, the manager said she had already spoken to staff about cleaning it up. St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 16 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 Quality in this outcome area is adequate. This judgement has been made using available evidence including a visit to the service. Residents are supported by trained staff in adequate numbers but would be better protected if recruitment checks were in place before staff begin work. EVIDENCE: The rota clearly showed four care staff until 2pm, then three between 2 and 8pm, during the week. At weekends there would be three care staff all day. The manager or deputy manager are on duty during the week and weekends. The home also employs a cook and two cleaners. Two night staff are on duty from 8pm and are awake all night. Staff felt the staffing ratio was sufficient although they would sometimes like to spend more time chatting with residents. The home has had an ongoing programme for staff to complete the National Vocational Award, (NVQ) in Care, Level 2. To date, nine staff have completed this and thirteen are currently studying. Seven staff are currently studying for NVQ3 and the deputy manager has achieved NVQ4 in care and the Registered Manager’s Award. Whilst the number of qualified staff does not yet meet the 50 ratio suggested by the standard, the home has a commitment to training more staff, and to a higher level than suggested by the standard. This standard is therefore met. Prospective new staff complete an application form and the manager or the deputy interviews them, and keeps a record. The inspector looked at the recruitment file for one staff member and found that the person was employed St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 17 two months before the Criminal Records Bureau check was completed. The manager said she had sought advice on this from the management company who were involved at the time and was advised against obtaining a POVAFirst, (Protection of Vulnerable Adults) check. There were two references in place, but the date they were received was not recorded so it was not possible for the home to evidence that they had been received before the person started work. Recruitment checks must be in place before new staff can start work and the manager was referred to the Commission’s website for further guidance to the regulations. Staff said the training offered was, ‘really good, excellent’, and that they could ask for extra training which would be sought, for example, and external course on dementia. The manager said a lot of input had been given to staff through training, coaching, guiding and leading. Core training such as Food Hygiene, Moving and Handling, Health and Safety, Fire Safety and First Aid is provided in house by the manager who has qualifications which enable her to do this. However, some staff had not received a Moving and Handling refresher which had been due in earlier in the year. The manager said this was due to the volume of training being provided, including NVQs, but that all staff were booked on a course in August. Not all staff have attended Fire Safety training but this is detailed in standard 38. New staff undergo a formal induction which is based on the national core induction standards, and is completed within ten weeks of beginning employment. St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 18 Management and Administration The intended outcomes for Standards 31 – 38 are: 31. 32. 33. 34. 35. 36. 37. 38. Service users live in a home which is run and managed by a person who is fit to be in charge, of good character and able to discharge his or her responsibilities fully. Service users benefit from the ethos, leadership and management approach of the home. The home is run in the best interests of service users. Service users are safeguarded by the accounting and financial procedures of the home. Service users’ financial interests are safeguarded. Staff are appropriately supervised. Service users’ rights and best interests are safeguarded by the home’s record keeping, policies and procedures. The health, safety and welfare of service users and staff are promoted and protected. The Commission considers Standards 31, 33, 35 and 38 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 31, 33, 35, 36 & 38 Quality in this outcome area is adequate. This judgement has been made using available evidence including a visit to the service. The home is managed by an experienced manager and views are sought about life in the home. Residents would be better protected if all staff had updated training in fire safety and if doors were held open in accordance with fire safety procedures. EVIDENCE: The manager has a considerable number of years experience of managing care in a number of settings and has been particularly involved in training. The manager achieved the Registered Manager’s Award last year. The home’s deputy is also experienced and has obtained NVQ Level 4 in management and care. The last quality assurance survey to be completed by relatives was last year. The manager is due to send out the questionnaires soon but was waiting for the building work to start. The results are then analysed and published, along with any responses or action taken. The manager also sends a questionnaire to St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 19 staff, which offers an opportunity for staff to make suggestions for improvements. The home does not look after any money on behalf of the residents. Staff said they were supervised and that they could talk to the management team about their work. Supervision takes the form of one to one sessions every two to three months, annual appraisals, observation twice a week by the deputy manager regarding practice, monthly team meetings and practice workshops every two weeks. An external fire safety company completes regular checks on equipment such as emergency lighting and extinguishers. In house checks such as testing the alarms are also conducted regularly. The majority of doors have been fitted with a device which allows them to be held open, but also to close automatically if there were to be a fire. However, one door which was labelled as a fire door leading to two bedrooms had this equipment, but it was not working and the door was wedged open with a cushion. Another bedroom door labelled as a fire door was wedged with a chair, although the manager found that the closure device was working. Two other bedroom doors were wedged open with chairs and did not have the automatic device fitted: the manager said that the remaining doors were due to be fitted with the device. A number of staff have not attended fire safety training updates which should be attended twice a year. There was evidence that the manager had stressed the importance of staff attending the training but they had not, and the manager had not set another date. Certificates were available regarding the maintenance of equipment such as the specialist bath, stairlift and hoists. Hazardous substances are stored securely. St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 20 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 X N/A HEALTH AND PERSONAL CARE Standard No Score 7 3 8 3 9 2 10 3 11 X DAILY LIFE AND SOCIAL ACTIVITIES Standard No Score 12 3 13 3 14 3 15 3 COMPLAINTS AND PROTECTION Standard No Score 16 3 17 X 18 2 3 X X X X X X 2 STAFFING Standard No Score 27 3 28 3 29 2 30 3 MANAGEMENT AND ADMINISTRATION Standard No 31 32 33 34 35 36 37 38 Score 3 X 3 X N/A 3 X 2 St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 21 Are there any outstanding requirements from the last inspection? NO 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 OP9 Regulation 13 (2) Requirement Robust medication procedures must be followed including: • A record must be made of the medication entering the home, and an audit trail must be possible. • Out of date medication must be disposed of. • All prescribed medication must be securely kept – this includes eye drops in the fridge. Staff must be aware of the procedures to follow in the event of an allegation or suspicion of abuse in the home. The laundry must be thoroughly cleaned, and kept clean, pending re-location. The relevant satisfactory recruitment checks must be in place before new staff begin work. • The registered manager must ensure all staff receive fire training twice in a twelve month period. • Advice from the fire safety officer regarding doors not DS0000062111.V299199.R01.S.doc Timescale for action 31/08/06 2 OP18 13 (6) 31/08/06 3 4 OP26 OP29 13 (3) 19 31/08/06 31/08/06 5 OP38 23 (4) 31/08/06 St Elmo Care Home Version 5.2 Page 22 being wedged open must be followed. 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 St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 23 Commission for Social Care Inspection Hampshire Office 4th Floor Overline House Blechynden Terrace Southampton SO15 1GW 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 St Elmo Care Home DS0000062111.V299199.R01.S.doc Version 5.2 Page 24 - Please note that this information is included on www.bestcarehome.co.uk under license from the regulator. Re-publishing this information is in breach of the terms of use of that website. Discrete codes and changes have been inserted throughout the textual data shown on the site that will provide incontrovertable proof of copying in the event this information is re-published on other websites. 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