Inspection on 18/01/06 for Theobald House

This inspection was carried out on 18th January 2006.

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

The inspector found there to be outstanding requirements from the previous inspection report. These are things the inspector asked to be changed, but found they had not done. The inspector also made 6 statutory requirements (actions the home must comply with) as a result of this inspection.

Other inspections for this house

Theobald House 05/11/08

Theobald House 15/02/07

Theobald House 19/08/05

Theobald House 28/02/05

Theobald House 27/05/04

Similar services:

2 Perhaver Park

The Vicarage

7 Hyde Road

St George`s

5 Seafield Road

Credence House

Radfords

Trevaylor Manor

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

CARE HOME ADULTS 18-65 Theobald House 46 Dartmouth Avenue Bath Bath & N E Somerset BA2 1AT Lead Inspector Sarah Webb Unannounced Inspection 18th January 2006 08:30 Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 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 Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 2 This is a report of an inspection to assess whether services are meeting the needs of people who use them. The legal basis for conducting inspections is the Care Standards Act 2000 and the relevant National Minimum Standards for this establishment are those for Care Homes for Adults 18-65. 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. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 3 SERVICE INFORMATION Name of service Theobald House Address 46 Dartmouth Avenue Bath Bath & N E Somerset BA2 1AT 01225 338567 01225 338567 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) None New Era Housing Association Limited Mrs Carol Christine Fyrth Care Home 4 Category(ies) of Learning disability (4), Physical disability (2) registration, with number of places Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 4 SERVICE INFORMATION Conditions of registration: 1. May accommodate up to 4 persons aged 18 - 65 years requiring personal care only 19th August 2005 Date of last inspection Brief Description of the Service: Theobald House is a care home operated by New Era, an independent voluntary organisation, to accommodate up to four people - two with a learning disability and two with a learning and physical disability. Bath and North East Somerset Council own the building.The home is situated in the Oldfield Park area of Bath in a quiet cul-de-sac. The home is within a five minute walk of Moorland Road, which offers a range of facilities including grocery stores, florists, shoe shops and hairdressers. Bath city centre is only a five minute drive from the house. The house itself is modern in design and offers accommodation on two floors. There are six single bedrooms in total, two on the ground floor, one of which is equipped with a wash hand basin, and four on the first floor, two of which are used by two staff members who provide sleepin cover. There are two communal lounge areas, and a dining room on the ground floor. The home provides sufficient bathrooms and toilets; the ground floor bathroom is equipped with a ceiling track hoist, and an adapted whirlpool bath facility. The home has specific equipment for service users accommodated based on an assessment of their individual need. There is ongoing discussion concerning the reconfiguration of the building in order to provide a suitable environment and meet the assessed needs of 2 individuals. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. This inspection was carried out as an unannounced inspection and took place over a period of 1 day and a total of 5 hours. The inspection methods used included observation of documentation, record checks, case tracking and discussion with the manager and 1 member of staff. New Era has recently joined forces with New Support Options to form the organisation New Dimensions. There has been ongoing training for all staff in the person centredness. There were 2 individuals at the home; it was not possible to have in-depth discussions with individuals due to their communication difficulties. However it was evidenced through the inspection process that staff continue to have a good understanding of individuals needs and maintain good relationships. The home is still in the process of deciding how the reconfiguration of the home is to be implemented. Previous plans drawn up to extend the building are currently being changed due to concerns from the staff team. What the service does well: What has improved since the last inspection? Statutory training for staff has been updated. Staff have received fire instruction and attended fire drills on a regular basis. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 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. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 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 Outcomes Statutory Requirements Identified During the Inspection Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 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 the following standard(s): 2 The assessed needs and preferences of individuals are met and there are processes in place for the review of their care. The staff have a good understanding of individuals’ support needs through the maintenance of positive relationships. EVIDENCE: As at previous inspections, there have been no changes since the last inspection, in relation to the four people accommodated at the home. Three of the four people have lived together at the home for many years. The fourth person was admitted in 1999. There was documentation in place evidencing that individuals are funded by the local authority and had been admitted to the home through the care management process. The home continues to work closely with specialist services in order to support individuals and offer advice to staff. A staff member said the home continues to work with individuals through a specific form of communication called Intensive Interaction. They said the approach created communication openings for individuals. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 9 A requirement for the manager to be provided with an easy to understand document, which clearly sets out the fee charges that relate to the individual service users and how these fee charges are made up has been partly met. Although the manager has not been provided with a specific document, she was able to evidence that some individual’s documentation in place clarified how fee charges are made up. Records indicated that an individual had been referred to a specialist service regarding the management of their behaviour. Another person had been referred for physiotherapy assessment at their day care placement. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 10 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 the following standard(s): 6 8, & 9 There is a clear and consistent care planning system in place to provide staff with the information they need to satisfactorily meet individual needs. However the home needs to complete the review of 2 individuals plans. There are procedures in place in seeking individuals’ views through staffs’ knowledge and understanding of specific communication needs. The home has risk management procedures in place to ensure individuals are supported safely in taking risks. EVIDENCE: It was evident through observation and discussion with both the manager and a staff member that care plans provide comprehensive information for staff in order to meet needs of individuals; this included communication needs, mobility, current daily routines, health checks and risk assessments. The manager said that the home aims to review care plans 6 monthly. Whilst two residents care plans had been reviewed, the remaining two are in need of being updated. Those care plans observed were all up to date and had been reviewed, signed and dated. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 11 The manager said that staff act on behalf of people with knowledge and understanding of their communication needs. Both the manager and a staff member said they would recognise if an individual was happy, or in distress. Individuals do not participate in aspects of carrying out household tasks. One person helps with their laundry. Risk assessments in place had been reviewed and included those covering areas such as bathing, travelling in the mini bus, and manual handling. Also areas of individuals behaviours that may pose a risk to their health and safety. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 12 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 the following standard(s): 12, 13, 15. Individuals are involved in meaningful and appropriate activities. Links with the community continue to be positive and support and enrich individuals lifestyle. The home supports and maintains individuals with their family relationships. EVIDENCE: The manager said that since the last inspection, there have been some residents’ activities that have not been covered due to staffing difficulties. This has now been rectified and has been recorded in Standard 33. Residents annual summer holiday were also affected by the staff shortages with just 1 person able to go on holiday. Through discussion with a staff member it was evident that some individual activities have been maintained, such as horse riding. It was evident through discussion with staff and observation of records that individuals have continued to access opportunities in the local community. This included shopping trips to the town, eating out in restaurants and public houses, and shows. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 13 The four residents also attend an external planned day service. It was also evident that individuals are supported on 1:1, and through the staffs’ knowledge of their preferences and needs., they are supported in making appropriate choices. A specialist service had supported an individual in the purchase of a touch screen computer. The home has secured the transport for another 6 months through use of a leased minibus; individuals continue to contribute a proportion of their mobility allowance to cover the cost. All residents pay the same cost even though there are some who do not benefit as much as others. Since the last inspection, alternative transport has been considered. An external advocacy agency has supported an individual in looking at alternatives, but there have been no solutions as yet. As at the last inspection the organisation’s charging policy for transport is still under review. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 14 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 the following standard(s): 18, 19, & 20 Personal support is offered in such a way to promote and protect individuals’ privacy, dignity, independence and preference. The physical and emotional health needs of individuals are well met with evidence of multi disciplinary working taking place regularly. The practice for the administration of medication to residents is good with clear and comprehensive arrangements being in place to ensure medication needs are met. However the current arrangements for staff in relation to the homes homely remedies policy is not following the homely remedies policy. are in need of being reviewed EVIDENCE: There is no change in that all of the residents are dependent on staff to meet their care needs. Specific, detailed care plans were in place to direct staff in supporting individuals with their personal care and mobility. A key worker system operates in the home; all four residents continue to have two key workers; this practice ensures consistency and continuity of support to individuals. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 15 Individuals are registered with a local GP Practice. Comprehensive records in place evidenced that individuals’ physical and mental health needs are monitored on a regular basis. There are no service users who self medicate. Records held for the administration and disposal of medication were well maintained. It was evident through observation of records of prn medication that the home currently has the practice for both staff and service users to make use of paracetamol stored at the home. The home is in the process of reviewing its homely remedies policy and manager has been advised that staff should bring in their own homely remedies. A separate record should be kept for staff if they make use of this medication if stored in the home. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 16 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 the following standard(s): 22 & 23 The home has a satisfactory complaints system with evidence that individuals’ concerns are understood and acted upon. The financial arrangements in the home are in need of improving in order that individuals are protected from possible financial abuse. EVIDENCE: No complaints have been received by the home since the last inspection. As residents are not able to vocalise their views both the staff and families advocate for individuals; it was evident through discussion with the manager and a staff member that individuals are able to make themselves understood through physical gestures, body language and vocalisations. The manager said the home has good relationships with families and was confident that they would be told of any concerns. The home has a formal policy and procedure on the Protection of Vulnerable Adults. There are procedures in place for staff to raise concerns. The majority of staff completed training in the protection of vulnerable adults several years ago. It is recommended that this is up dated through Bath and North East Somerset in line with changes to the local authority inter agency policies and procedures and that staff are updated of any changes. Residents are unable to manage their own financial affairs. The manager continues to be appointee for three individuals’ savings accounts. The family of the fourth person manage their finances. It was evident through observation of records and through discussion with the manager that the financial practices in the home need to be improved. An individuals’ building society book is in need of being up dated and a cheque is in need of being banked. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 17 Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 18 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 the following standard(s): 24 Although the standard of décor provides homely and comfortable surroundings the organisation is failing to provide a safe and suitable environment to meet the needs of an individual. EVIDENCE: Since the last inspection there has been change in the arrangements for the maintenance of the garden and some areas of the home. The manager said she would contact the organisations property services initially. She may need to gather quotes for certain repairs to be carried out and it was evident that this system takes longer for repairs to be implemented. Since the last inspection there has been a water leak coming from a first floor bathroom. This has affected the office area with carpeting having to be removed due to damp. It was also noted that the water has permeated through to a ground floor bedroom. The manager said that this is now becoming a long standing repair covering a 2 month period. Although the leak is not so significant now, a requirement has been made for repairs to be carried out within 4 weeks. The manager is to inform the Commission when this has been met; if unmet within the timescale an immediate requirement will be issued. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 19 A requirement has not been met to provide a safe and suitable environment in order to meet the needs of 2 indivdiuals. The manager said that previous plans for the extention of the property and to admitt 2 extra residents had been opposed by staff. It is evident that the organisation has listened to the staff’s concerns and as the residents are unable to express their views verbally, the staff have advocated for individuals through their knowledge and understanding of their needs. The manager said the organisation is committed to the reconfiguration of the building in providing a suitable environment especially for 1 specific individual whose bedroom is only 6.3 sq metres of usable floor space and is not suitable for their needs. Although another bedroom is also below the required level of usable space, the manager said this was not such an issue as staff are able to support this person sufficiently with their personal needs and that the individual is not confined by the size of the room due to their restricted mobility needs. Through observation of documentation it is evident that New Era are making steps to clarify if Western Challenge are interested in taking on the lease of the property, after New Era sign up to a new lease for 45 years with the local authority, and after building works have been completed. If this was to take place, New Era would then enter into a management agreement with Western Challenge and the residents tenancies would transfer over after consultation. Although the process is slow a further requirement is made for the organisation to keep the Commission informed of all developments pertaining to building works. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 20 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 32, 34 and 35 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 32, 33 & 35 The home has an effective and competent staff team supporting the needs of individuals. Residents are supported by regularly trained staff. EVIDENCE: Five of the eight care staff have achieved a qualification in National Vocational Qualification Level 3 with another in the process. The deputy manager also has a level 4 qualification. This meets Standard 32.6 in that 50 of the staff team have achieved a National Vocational Qualification. There are currently no staff vacancies. However, the manager said that the home has had staffing difficulties in relation to covering long term sickness, paternity and annual leave, and training. The manager said this has now been rectified through arrangements for care bank staff to cover sleep in shifts in order to free up staff to carry out daytime activities with individuals. It was evident through observation and discussion with a staff member that the staff team work well together and that there is an openness and willingness to try out new ideas. Staffing records evidenced that statutory training of manual handling , first aid, and food hygiene is up to date. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 21 Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 22 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 37, 39, and 42 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 39, 41 and 42 There are procedures in place to seek the views of individuals through advocates, staff and families. The home needs to improve the recording of individuals financial so that individuals’ interests and rights are safeguarded. The home needs to improve in the fire safety arrangements in order to protect the health and safety of both residents and staff. EVIDENCE: The manager said the home has informal procedures in place seeking the views of families. Placement and Annual reviews form a focus for discussion and in obtaining their views as to the satisfaction of the service. There are formal consultation processes in place that have been used by the organisation for families and residents to express their views and make comment. With the recent change within the organisation, families and residents have been included in both social and formal consultation events. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 23 A requirement has been met to ensure all staff receive fire instruction and attend fire drills on a regular basis bar 1 staff member who was unavailable on the day of training. The manager said this is in hand. It was evident through the fire safety log that fire equipment has not been tested on a consistent basis. A requirement is made for all fire equipment to be maintained in line with the both the organisational and homes procedures. Currently managers cascade fire training to their staff team. The manager has concerns as to taking on the responsibility of training staff due to conflicting advice that has been given by local fire officers and for the need for staff to be informed of current safe practice. Due to this uncertainty it was evident through discussion with both the manager and a staff member that there is ongoing discussion regarding the fire safety procedures of the home. A requirement is made for a review to be carried out of the homes fire procedures providing clarity regarding both daytime and night time procedures. The home also needs to carry out risk assessments in relation to the specific fire safety needs of individuals. Those records seen, such as Gas Safety certificate, electrical testing, servicing of disability equipment, and accidents were up to date. Other records seen have been included in the appropriate section of this report including the financial arrangements of individuals in Standard 23. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 24 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 Standard No Score 1 x 2 3 3 x 4 x 5 x INDIVIDUAL NEEDS AND CHOICES Standard No 6 7 8 9 10 Score CONCERNS AND COMPLAINTS Standard No Score 22 3 23 2 ENVIRONMENT Standard No Score 24 1 25 x 26 x 27 x 28 x 29 x 30 x STAFFING Standard No Score 31 x 32 3 33 3 34 x 35 3 36 x CONDUCT AND MANAGEMENT OF THE HOME Standard No 37 38 39 40 41 42 43 Score 3 x 3 3 x LIFESTYLES Standard No Score 11 x 12 3 13 3 14 x 15 3 16 x 17 x PERSONAL AND HEALTHCARE SUPPORT Standard No 18 19 20 21 Score 3 3 2 x x x 3 x 2 2 x Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 25 YES 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. 2. Standard YA6 YA24 Regulation 15 23(2) Requirement Complete the review of 2 individuals care plans Keep the Commission informed of how the change in the reconfiguration of the home is to be implemented including plans and timescales Carry out plumbing repairs to the first floor bathroom Timescale for action 28/02/06 30/04/06 3. 4. 5. YA24 YA20 YA23 23(2) 13(2) 12(1) 15/02/06 6. YA42 23(4) Keep separate supplies and 18/01/06 records for staff in the taking of homely remedies. 1) Update individuals’ building 18/01/06 society book. 2) Deposit cheque in individuals account. 1) Review current fire safety 18/01/06 procedures in the event of an outbreak of fire. 2) Risk assess individuals’ specific needs in the event of an outbreak of a fire. 3) Ensure fire equipment is maintained on a consistent basis. Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 26 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 Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 27 Commission for Social Care Inspection Bristol North LO 300 Aztec West Almondsbury South Glos BS32 4RG 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 Theobald House DS0000008181.V276207.R01.S.doc Version 5.1 Page 28 - 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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