Inspection on 02/05/08 for Sunningdale

This inspection was carried out on 2nd May 2008.

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 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

Sunningdale 23/04/09

Sunningdale 03/05/06

Sunningdale 06/12/05

Sunningdale 31/05/05

Sunningdale 14/10/04

Sunningdale 19/07/04

Extracts from inspection reports are licensed from CQC, this page was updated on 28/09/2008.

CARE HOMES FOR OLDER PEOPLE Sunningdale 5 North Park Road Manningham Bradford West Yorkshire BD9 4NB Lead Inspector Steve Marsh Key Unannounced Inspection 2nd May 2008 09:30 X10015.doc Version 1.40 Page 1 The Commission for Social Care Inspection aims to: • • • • Put the people who use social care first Improve services and stamp out bad practice Be an expert voice on social care Practise what we preach in our own organisation Reader Information Document Purpose Author Audience Further copies from Copyright Inspection Report CSCI General Public 0870 240 7535 (telephone order line) This report is copyright Commission for Social Care Inspection (CSCI) and may only be used in its entirety. Extracts may not be used or reproduced without the express permission of CSCI www.csci.org.uk Internet address Sunningdale DS0000060012.V363832.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. Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 3 SERVICE INFORMATION Name of service Sunningdale Address 5 North Park Road Manningham Bradford West Yorkshire BD9 4NB 01274 545859 01274 543265 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) Crabtree Care Homes Mrs Georgina Melvin Care Home 40 Category(ies) of Dementia (40) registration, with number of places Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 4 SERVICE INFORMATION Conditions of registration: 1. The registered person may provide the following category of service only: Care home only - Code PC, to service users of the following gender: Either, whose primary care needs on admission to the home are within the following category: Dementia - Code DE The maximum number of service users who can be accommodated is: 40 3rd May 2006 2. Date of last inspection Brief Description of the Service: Sunningdale is a 40 bedded home for people with dementia, some of whom may be under 65. The home is situated in the Manningham area of Bradford overlooking the park. A main bus route is close by. The home is operated by Crabtree Care Homes, which is a family run business. The building, a large Victorian house has been extended to provide additional single en suite bedrooms. Accommodation is on two floors with passenger lift access. Some of the very large rooms in the older part of the house are shared between two people. The walled garden surrounding the property has a parking area and has been pleasantly landscaped to provide secure outdoor walking and sitting areas. This allows residents the freedom to wander in and out of the house without restriction. Access to the property is through electric gates controlled with the help of CCTV cameras by staff from inside the house. The fees at the time of writing range from £380:00 to £450:00 per week. The following services are not included in the fees, Hairdressing, Chiropody (private), personal clothing and toiletries and outings. A charge may be made to cover additional staff time needed for hospital escort duties. Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. The quality rating for this service is two star. This means the people that use the service experience good quality outcomes. The inspection process included looking at the information we have received about the home since the last key inspection, as well as this unannounced visit to the home, which was carried out between 09:30 and 17:00hrs. The purpose of this inspection was to assess what progress the service had made in meeting the requirements made in the last inspection report and the impact of any changes in the quality of life experienced by people living at the home. The methods we used included looking at records, watching staff at work, talking to people living at the home and their relatives, talking with staff and looking around the property. As some people were unable to express their views and opinions of the service due to their illness observation was used to see how they spent their day and interacted with staff. The manager had also completed an annual quality assurance assessment form and the information provided has also been used as evidence in the report. Feedback was given to the manager at the end of the visit. What the service does well: The providers and manager have a positive approach to the inspection process, are aware of the shortfalls in the service and shows a willingness to work with us to maintain and improve standards. The manager and staff are approachable, have a caring attitude and try hard to create a homely atmosphere. Relatives said that the care staff appear to have the right mix of skills and experience, and that all the staff are caring and sympathetic to the individual’s needs. The information provided about the service is good and gives people the opportunity to decide whether or not the home can meet their needs. Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 6 The admission procedure is thorough and the manager will not admit people unless she feels that the staff can provide the level of care and assistance they require. The home provides a safe and comfortable environment for people, all concerns/complaints are taken seriously, and action is taken to resolve matters. What has improved since the last inspection? 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. The summary of this inspection report can be made available in other formats on request. Sunningdale DS0000060012.V363832.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 Sunningdale DS0000060012.V363832.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. JUDGEMENT – we looked at outcomes for the following standard(s): 1, 3 and 5 – standard 6 is not applicable to this service. People who use this service experience good quality outcomes in this area. This judgement has been made using available evidence including a visit to this service. People’s needs are assessed before they are admitted and they can visit and stay for a trial period to make sure that the home is right for them. EVIDENCE: The information provided about the service is good and gives people the opportunity to decide whether or not the home can meet their needs. The records showed that people’s needs are assessed before they move into the home. The manager told us that people are encouraged to visit before making a decision about moving in although in many cases it is relatives who visit on behalf of the person needing care. People offered a place at the home are always supported throughout the admission process and care is taken to make sure they settle into their new environment. The first six weeks of their stay is classed as a trial period. This Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 9 gives people the opportunity to experience at first hand the standard of care and facilities provided. The manager told us that people are given a statement of the terms and conditions and a contract at the time of admission. The manager confirmed that home does not take emergency admissions under any circumstances. Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 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. JUDGEMENT – we looked at outcomes for the following standard(s): 7, 8, 9 and 10. People who use this service experience good quality outcomes in this area. This judgement has been made using available evidence including a visit to this service. People’s healthcare and personal needs are generally met in a way that maintains their dignity and independence. However, care plans do not always give staff clear guidance, which means that care may not always be given in a way that takes account of people’s individual preferences and abilities. EVIDENCE: Care plans have been completed for all people living at the home, which cover all aspects of their social and healthcare needs. There was some evidence to show that wherever possible people are involved in the care planning process, which means that they are consulted about, how they want their care and support to be provided. The four care plans reviewed were completed to a satisfactory standard. However, in some instances the care plans were not specific enough and did not identify people’s abilities or the areas where they need support to carry out daily activities. The care plans for one person known to become agitated and Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 11 physically aggressive at times did not make it clear how staff should respond to this behaviour. All people living at the home are registered with a general practitioner and are supported in having access to the full range of NHS services. The input of other healthcare professionals is clearly recorded in the documentation available, which shows that staff are seeking advice if they have concerns about an individual’s health. People said that they were generally pleased with the care and attention they received. Comments included “I am well looked after and staff always call a doctor if I am feeling unwell” and “I have no complaints about the care and support I receive.” Relatives said that they were pleased with the standard of care and facilities provided and staff treated people with respect and were always willing to do anything to assist them. Moving and handling and nutritional assessments are routinely completed for all new admissions and risk assessments are completed, where areas of potential risk to people’s general health or welfare are identified. People are weighed on a monthly basis however we found that staff are not always using the weighing scales correctly and are recording substantial weight losses without reporting the matter to the manager for investigation. This is unsafe practice and might lead to people’s health care being put at risk. The manager said this matter would be addressed immediately. On reviewing the medication system we found that overall medicines are managed safely. However, a stock control system needs to be put in place for medication administered on a PRN (as and when required) basis so that people can be confident it is being given as prescribed. One of the two drug trolleys in use also requires securing to the wall and controlled drugs must be stored in line with current legislation. Since the inspection the providers have confirmed that a new controlled drugs cupboard will be installed within the next three months. No one in the home manages his or her own medicines. Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 12 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. JUDGEMENT – we looked at outcomes for the following standard(s): 12, 13, 14 and 15. People who use this service experience adequate quality outcomes in this area. This judgement has been made using available evidence including a visit to this service. More could be done to provide people with a more extensive range of recreational and leisure activities both within the home and the wider community. Meals are nourishing and take into account people’s likes and dislikes. EVIDENCE: The manager said that the daily routines are flexible and people are encouraged to make choices about how they will spend their time whilst living at the home. Through discussions with staff and people living at the home it is apparent that only limited social and leisure activities take place. No one has specific responsibility for organising social activities and therefore it is left to care staff to do what they can when they have time. There are however plans to employ an activities co-ordinator, which will greatly improve the service and people’s quality of life. Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 13 People said that they enjoyed going out into the garden, walks in the park and watching the large screen televisions. They also said that they enjoyed the entertainers that perform at the home on a monthly basis, but did spend a lot of time with not a great deal to do. The manager confirmed that she is aware that more could be done to provide people with a more stimulating environment and in the near future staff are to attend in-house training on Cognitive Stimulation Therapy (CST). CST is an evidence based group treatment for people with mild to moderate dementia, which initially involves fourteen sessions of stimulating, themed activities. The manager said people are encouraged to attend their place of worship if they wish to do so and where people are unable to express their wishes due to their illness the home consult with family and friends. Relatives said that they are able to see people in their own room if they wish to do so and confirmed that visitors were always made to feel welcome and offered light refreshment. Mealtimes are sociable occasions and each person takes all the time they need to eat their meal. There is a good choice of dishes on the menu, and alternatives are offered if people prefer something different. Staff are aware of people’s needs and preferences and assistance is offered discreetly to people who are not able to manage to eat independently. Hot and cold drinks are freely available to people both day and night. Comments from people included “the food is very good and I look forward to my meals” and “I have no complaints at all about the food – we certainly get well fed.” Following a recent Food Hygiene Inspection by the Environmental Health Department the home was awarded a four star rating (out of a possible 5 stars). Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 14 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. JUDGEMENT – we looked at outcomes for the following standard(s): 16 and 18. People who use this service experience good quality outcomes in this area. This judgement has been made using available evidence including a visit to this service. Robust complaint and adult protection policies and procedures ensure that people are listened to, and protected from any form of abuse. EVIDENCE: There is a clear complaints procedure available and people that were able said that they would have no problems approaching the manager if they had any concerns about the standard of care being provided. The manager confirmed that no complaints have been received in the last year. Adult protection policies and procedures are in place although some staff have still to attend a training course on the recognition and reporting of abuse. A date has been arranged for this training to take place. Staff spoken with said that they were aware of the home’s policy on “whistle blowing” and their responsibility to safeguard people living in the home from any form of abuse. Policies and procedures are in place to protect people from financial abuse, which precludes staff from being involved in the making of, or benefiting from people’s wills. Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 15 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. JUDGEMENT – we looked at outcomes for the following standard(s): 19, 20, 21, 24 and 26. People who use this service experience good quality outcomes in this area. This judgement has been made using available evidence including a visit to this service. The home provides people with a pleasant and comfortable environment in which to live. EVIDENCE: A new extension has recently been opened at the home, which includes eight single en-suite bedrooms and additional communal facilities. The kitchen and laundry room have also been extended. All the communal areas including lounges and the dining room are situated on the ground floor of the home, conveniently close to toilet facilities. The standard of décor and furnishing is good and they are pleasant areas for people to take their meals and relax. Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 16 Bedrooms are located on both floors of the home and consist of thirty single and five double rooms most of which have en-suite facilities. All bedrooms are comfortably furnished and the majority are light and spacious. People are encouraged to bring personal possessions into the home, which makes each room look individual and homely. Communal bathrooms and toilets are located throughout the home and the general standard of fixture and fittings was found to be good. The manager is aware that two toilets on the ground floor need refurbishing and confirmed that this work would be carried out within two weeks of the visit. We asked the manager to confirm in writing that the work had been completed. People said that they were very happy with the standard of accommodation, and were pleased that they had been able to furnish their rooms with personal possessions. On the day of the visit the home was clean and tidy and free from offensive odours. Externally the grounds are safe, secure and very well maintained. There are electronic gates to the main entrance to the home which means that people living there are able to use the garden area unescorted without the fear of them wandering off. Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 17 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. JUDGEMENT – we looked at outcomes for the following standard(s): 27, 28, 29 and 30. People who use this service experience good quality outcomes in this area. This judgement has been made using available evidence including a visit to this service. There are sufficient staff employed on day and night duty to meet people’s needs. However, recruitment and selection procedures must be followed to make sure that people living at the home are protected. EVIDENCE: The staff rota showed that sufficient staff are employed on day and night duty to meet people’s needs. Since purchasing the home the providers have established a stable staff team with a good mix of skills and cultural backgrounds. Recruitment and selection procedures are in place, which include checking the Protection Of Vulnerable Adult (POVA) register and obtaining at least two written references and a Criminal Record Bureau (CRB) report before new staff are permanently employed. We looked at the employment files of four staff. Generally the files were in good order and in three files we found that all the required checks had been completed before people started work. However, in one instance the CRB and one reference for a senior member of staff had not been received until after her start date. There was also no evidence to suggest that the POVA register had been checked before she was employed. Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 18 The manager confirmed that all new staff receive induction training using the Skills for Care Common Induction standards. These are nationally agreed induction standards designed to help new staff get the skills and knowledge they need to care for people. Following induction training there is an expectation that staff will study for a National Vocational Qualification (NVQ) at either level two or three depending on the post they hold. On the day of the visit the manager had difficulty finding some records relating to staff training, due in part to her office being relocated. Since the inspection the Human Resource manager for Crabtree Care Homes has provided us with a staff-training matrix, a training development plan and confirmation that all staff now have an individual training and development plan in place. Training courses planned in the near future includes dementia awareness, dealing with challenging behaviour and the protection of vulnerable adults. Staff said that while they had attended some training courses in the last year they felt that training opportunities were limited. Some felt that more inhouse training should be made available to them specific to the needs of the people living at the home. The training plan for 2008/09 should address this matter. Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 19 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. JUDGEMENT – we looked at outcomes for the following standard(s): 31, 33, 35, 36 and 38. People who use this service experience good quality outcomes in this area. This judgement has been made using available evidence including a visit to this service. The home is well managed and the manager makes sure that people’s rights are protected. EVIDENCE: Mrs Georgina Melvin is the registered manager of the home however she confirmed that she is due to retire June 2008. A new manager has been appointed and will take up post in the near future. Mrs Melvin has many years experience in the caring profession and has achieved a National Vocational Qualification (NVQ) at level four in management and care and the Registered Managers Award (RMA). Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 20 The manager works within the home on a daily basis and therefore is on hand to deal with any queries/concerns raised by either the staff or people living there. There is evidence to show that staff have one-to-one supervision with the manager on a regular basis and an annual appraisal of their work. There is a range of quality assurance monitoring measures in place including sending out survey questionnaires to people living at the home, their relatives and visiting healthcare professionals. The survey gives people the opportunity to express their views of the service and is an important part of the quality assurance monitoring process. The manager was asked to forward us a summary of the next survey results indicating what action the home is taking to address any concerns or suggestions. The home holds money in safekeeping for a number of people and transaction sheets are in place showing income, expenditure and a balance. Only senior staff deal with financial transactions and regular audits are carried out to make sure the records are accurate and in good order. Receipts are obtained for any items purchased by staff on behalf of people. It was recommended to the manager that it would be good practice for two staff to sign the transaction sheets when ever possible. Information provided in the self–assessment form showed that all equipment in use at the home is serviced in line with the manufacturer’s guidelines. People can therefore be confident that all the equipment in use is in good working order. Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 21 SCORING OF OUTCOMES This page summarises the assessment of the extent to which the National Minimum Standards for Care Homes for Older People have been met and uses the following scale. The scale ranges from: 4 Standard Exceeded 2 Standard Almost Met (Commendable) (Minor Shortfalls) 3 Standard Met 1 Standard Not Met (No Shortfalls) (Major Shortfalls) “X” in the standard met box denotes standard not assessed on this occasion “N/A” in the standard met box denotes standard not applicable CHOICE OF HOME Standard No Score 1 2 3 4 5 6 ENVIRONMENT Standard No Score 19 20 21 22 23 24 25 26 3 X 3 X 3 N/A HEALTH AND PERSONAL CARE Standard No Score 7 2 8 2 9 2 10 3 11 X DAILY LIFE AND SOCIAL ACTIVITIES Standard No Score 12 2 13 3 14 3 15 4 COMPLAINTS AND PROTECTION Standard No Score 16 3 17 X 18 3 3 3 3 X X 3 X 3 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 3 3 X 3 Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 22 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 OP7 Regulation 15 Requirement Care plans must give clear guidance to staff on how people’s needs are to be met, so that people living at the home receive the level of care and support they require. People’s weight must be accurately taken and any significant weight loss investigated, so that their general health and wellbeing is not compromised. A new controlled drugs cupboard must be installed so that controlled drugs can be stored safely and in line with current legislation. An accurate stock control system must be maintained for medication administered on a PRN (as and when required) basis so that people can be confident that medication is being given as prescribed. Drug trolleys must be securely fastened to the wall. People must be offered a range of appropriate social and leisure DS0000060012.V363832.R01.S.doc Timescale for action 31/07/08 2. OP8 16 31/05/08 3. OP9 13(2) 29/08/08 4. OP9 13(2) 31/05/08 5. OP12 16(m) 31/07/08 Sunningdale Version 5.2 Page 23 6. OP29 19 activities so they have the opportunity to lead a full and active life. Recruitment and selection procedures must be followed so that people can be confident that they are being cared for by staff that are suitable to work in the caring profession. 31/05/08 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 OP35 Good Practice Recommendations It was recommended that two staff sign the financial transaction sheets when ever possible. Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 24 Commission for Social Care Inspection North Eastern Region St Nicholas Building St Nicholas Street Newcastle Upon Tyne NE1 1NB National Enquiry Line: Telephone: 0845 015 0120 or 0191 233 3323 Textphone: 0845 015 2255 or 0191 233 3588 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 Sunningdale DS0000060012.V363832.R01.S.doc Version 5.2 Page 25 - 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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