Care Home: Claremont House

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What the care home does well All 5 residents spoken with expressed a great deal of satisfaction regarding the quality of service they receive at Claremont House, a view echoed by all staff spoken to, including two visiting relatives. Their views including those of staff, have been reflected throughout the report. The home provides a planned and well managed service to the people accommodated, thus ensuring that individual needs are assessed and identified before the person moves to the home. The care plan is of a good standard and reflects how identified needs are being addressed. Review systems are in place, which involve the resident and their representative; their implementation ensure that identified health and personal care needs are being addressed and unmet needs, closely monitored. Activities offered to residents provide them with a good level of stimulation. Meals offered to residents are of a good standard. Quality and diversity issues are being promoted and residents are treated with dignity and respect. The accommodation is homely, comfortable and the quality of furniture and fittings is very good. A high standard of cleanliness was evident throughout those areas viewed. Residents are really appreciative of their physical environment. NVQ training for staff is being given a high profile. What has improved since the last inspection? The last key inspection carried out in January 2007 left no requirements or recommendations. Since the last inspection, the deputy manager has left; a new deputy manager joined the team in July 2009, which seems to have further enhanced the morale of the staff team. The level of training provided to staff has increased since the last inspection; staff have received all mandatory training and refreshers are arranged as necessary. Regular staff and resident meetings take place, which means that they have good opportunities to discuss and share their views on matters that affect them. Equally, management meetings are held, thus ensuring that care and staff management systems including health and safety are implemented to good effect. What the care home could do better: There are 2 requirements and 2 recommendations arising from this report, which need to be addressed. A current photograph of the staff must be available in their recruitment file as part of the proof of identity. This is to ensure the protection of residents. The manager must ensure that all staff receive training in the Mental Capacity Act and how it affects their work. This is so that they comply with it and ensure the protection of residents. Recommendations: The monthly review notes should be rationalised, recorded and retained in one place; this would offer a holistic overview to enable the manager take remedial action where required. Monthly review notes should reflect the full name and signature of the staff member undertaking the monthly review, at all times. Key inspection report Care homes for older people Name: Address: Claremont House Lovent Drive Leighton Buzzard Bedfordshire LU7 3LR     The quality rating for this care home is:   three star excellent service A quality rating is our assessment of how well a care home is meeting the needs of the people who use it. We give a quality rating following a full review of the service. We call this full review a ‘key’ inspection. Lead inspector: Neil Fernando     Date: 0 3 1 2 2 0 0 9 This is a review of quality of outcomes that people experience in this care home. We believe high quality care should • • • • • Be safe Have the right outcomes, including clinical outcomes Be a good experience for the people that use it Help prevent illness, and promote healthy, independent living Be available to those who need it when they need it. The first part of the review gives the overall quality rating for the care home: • • • • 3 2 1 0 stars - excellent stars - good star - adequate star - poor There is also a bar chart that gives a quick way of seeing the quality of care that the home provides under key areas that matter to people. There is a summary of what we think this service does well, what they have improved on and, where it applies, what they need to do better. We use the national minimum standards to describe the outcomes that people should experience. National minimum standards are written by the Department of Health for each type of care service. After the summary there is more detail about our findings. The following table explains what you will see under each outcome area. Outcome area (for example Choice of home) These are the outcomes that people staying in care homes should experience. that people have said are important to them: They reflect the things This box tells you the outcomes that we will always inspect against when we do a key inspection. This box tells you any additional outcomes that we may inspect against when we do a key inspection. This is what people staying in this care home experience: Judgement: This box tells you our opinion of what we have looked at in this outcome area. We will say whether it is excellent, good, adequate or poor. Evidence: This box describes the information we used to come to our judgement. Care Homes for Older People Page 2 of 27 We review the quality of the service against outcomes from the National Minimum Standards (NMS). Those standards are written by the Department of Health for each type of care service. Copies of the National Minimum Standards – Care Homes for Older People can be found at www.dh.gov.uk or bought from The Stationery Office (TSO) PO Box 29, St Crispins, Duke Street, Norwich, NR3 1GN. Tel: 0870 600 5522. Online ordering from the Stationery Office is also available: www.tso.co.uk/bookshop The mission of the Care Quality Commission is to make care better for people by: • Regulating health and adult social care services to ensure quality and safety standards, drive improvement and stamp out bad practice • Protecting the rights of people who use services, particularly the most vulnerable and those detained under the Mental Health Act 1983 • Providing accessible, trustworthy information on the quality of care and services so people can make better decisions about their care and so that commissioners and providers of services can improve services. • Providing independent public accountability on how commissioners and providers of services are improving the quality of care and providing value for money. Reader Information Document Purpose Author Audience Further copies from Copyright Inspection report Care Quality Commission General public 0870 240 7535 (telephone order line) Copyright © (2009) Care Quality Commission (CQC). This publication may be reproduced in whole or in part, free of charge, in any format or medium provided that it is not used for commercial gain. This consent is subject to the material being reproduced accurately and on proviso that it is not used in a derogatory manner or misleading context. The material should be acknowledged as CQC copyright, with the title and date of publication of the document specified. www.cqc.org.uk Internet address Care Homes for Older People Page 3 of 27 Information about the care home Name of care home: Address: Claremont House Lovent Drive Leighton Buzzard Bedfordshire LU7 3LR 01525852628 01525217242 claremonthouse96@aol.com Telephone number: Fax number: Email address: Provider web address: Name of registered provider(s): Type of registration: Number of places registered: Mr Derek Abreu care home 13 Conditions of registration: Category(ies) : Number of places (if applicable): Under 65 dementia old age, not falling within any other category physical disability Additional conditions: Date of last inspection Brief description of the care home Claremont residential home is a detached property, which is situated in a pleasant residential area close to Leighton Buzzard town centre. The home provides care for up to 13 older people over the age of 65 years. Residents bedrooms are personalised to meet individual taste and preference. All bedrooms have en-suite facilities; a communal bathroom and a toilet is also available on the ground floor. The lounge/diner is spacious and the standard of decoration, furniture and fittings are of a high standard. The home has adequate parking facilities to the front of the building. A copy of the service users guide and the last inspection report from the Commission is available at the home, for prospective residents and visitors to read. 0 0 0 Over 65 13 13 13 Care Homes for Older People Page 4 of 27 Summary This is an overview of what we found during the inspection. The quality rating for this care home is: Our judgement for each outcome: three star excellent service Choice of home Health and personal care Daily life and social activities Complaints and protection Environment Staffing Management and administration peterchart Poor Adequate Good Excellent How we did our inspection: The quality rating for this service is 3 stars. This means the people who use this service experience excellent quality outcomes. We, the Care Quality Commission, undertook this unannounced key inspection of this home on 3 December 2009, the last having occurred on 17 January 2007. We spoke with 5 residents, 2 visiting relatives, the owner/manager and deputy manager, and 4 staff including the cook. The visit also provided an opportunity to observe staff care practices; a range of documents the home must keep was viewed. We also undertook a brief tour of the home accompanied by the owner/manager. At the time of the visit, there were 13 residents accommodated, with no vacancy. Prior to the inspection, we received the AQAA (Annual Quality Assurance Assessment Care Homes for Older People Page 5 of 27 a document, which gives the manager the opportunity to tell us how well outcomes are being met for people living in the home); it provides a good level of details about the service. Surveys to seek the views of residents and staff were sent but we have been informed that the home has not received them; further surveys are being sent and any information received would be dealt with as appropriate. The Owner/manager and deputy manager were available throughout the inspection. Care Homes for Older People Page 6 of 27 What the care home does well: What has improved since the last inspection? What they could do better: There are 2 requirements and 2 recommendations arising from this report, which need to be addressed. A current photograph of the staff must be available in their recruitment file as part of the proof of identity. This is to ensure the protection of residents. The manager must ensure that all staff receive training in the Mental Capacity Act and Care Homes for Older People Page 7 of 27 how it affects their work. This is so that they comply with it and ensure the protection of residents. Recommendations: The monthly review notes should be rationalised, recorded and retained in one place; this would offer a holistic overview to enable the manager take remedial action where required. Monthly review notes should reflect the full name and signature of the staff member undertaking the monthly review, at all times. If you want to know what action the person responsible for this care home is taking following this report, you can contact them using the details on page 4. The report of this inspection is available from our website www.cqc.org.uk. You can get printed copies from enquiries@cqc.org.uk or by telephoning our order line 0870 240 7535. Care Homes for Older People Page 8 of 27 Details of our 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) Outstanding statutory requirements Requirements and recommendations from this inspection Care Homes for Older People Page 9 of 27 Choice of home These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: People are confident that the care home can support them. This is because there is an accurate assessment of their needs that they, or people close to them, have been involved in. This tells the home all about them and the support they need. People who stay at the home only for intermediate care, have a clear assessment that includes a plan on what they hope for and want to achieve when they return home. People can decide whether the care home can meet their support and accommodation needs. This is because they, or people close to them, have been able to visit the home and have got full, clear, accurate and up to date information about the home. If they decide to stay in the home they know about their rights and responsibilities because there is an easy to understand contract or statement of terms and conditions between them and the care home that includes how much they will pay and what the home provides for the money. This is what people staying in this care home experience: Judgement: People using this service experience good quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. Detailed information is available to anyone looking to move into the home, and the manager ensures an appropriate assessment is carried out before anyone can move in. This ensures that identified needs can be met. Evidence: The AQAA tells us Full assessment carried out by manager or the assistant manager to ensure effective care needs can be met. Prospective service user invited to spend the day at Claremont House. Information about the home including the statement of purpose and service users guide is offered to the prospective resident and their representative. A copy of each document is also available at the care home for the prospective resident and any visitors to read. Three residents and one visiting relative said that they were invited to visit and view the home before an offer of placement was made. Care Homes for Older People Page 10 of 27 Evidence: At the time of the inspection, there were thirteen residents accommodated. A random sample of case files for three residents were examined. They all have had an assessment of needs completed by the manager/deputy manager and a member of the care staff team. This is normally carried out during a visit to the person, or to their family, and looks not only at the care needs of the person but also at any equipment or aids they may need. A place is offered only if the home are happy that they are able to meet the needs identified during the assessment. Once the person has decided to move into the home, a contract/terms of residence is signed. A trial period of up to eight weeks is offered, in order to help the resident decide if they wish to live at the home on a longer term basis. The initial care plan is drawn up when the new resident first arrive at the home; a checklist is used by staff to ensure that all aspects of their support needs and the facilities available in the home are covered. Care Homes for Older People Page 11 of 27 Health and personal care These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: People’s health, personal and social care needs are met. The home has a plan of care that the person, or someone close to them, has been involved in making. If they take medicine, they manage it themselves if they can. If they cannot manage their medicine, the care home supports them with it, in a safe way. People’s right to privacy is respected and the support they get from staff is given in a way that maintains their dignity. If people are approaching the end of their life, the care home will respect their choices and help them feel comfortable and secure. They, and people close to them, are reassured that their death will be handled with sensitivity, dignity and respect, and take account of their spiritual and cultural wishes. This is what people staying in this care home experience: Judgement: People using this service experience excellent quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. The residents observed during the course of the visit appeared to be very well cared for and they were being treated with dignity and respect. Evidence: The care plan is developed with contribution from the resident, their representative and home staff. A random sample of care plans for three residents were viewed; care plans are detailed and comprehensive showing how the identified needs of residents are being met. Staff members record the care given, progress made and interactions with other people. Identified health care needs are being addressed and observations are maintained. This enables staff to respond to changes in good time, as noted from the records seen. The resident and their representative are encouraged to sign their care plan as appropriate. Care plans are being reviewed monthly by staff to reflect the changing needs and objectives for health and personal care. The review notes should be rationalised, recorded and retained in one place; this would offer a holistic overview to enable the manager take remedial action where required. Also, review notes should reflect the Care Homes for Older People Page 12 of 27 Evidence: full name and signature of the staff member undertaking the monthly review, at all times. Once the above issues are addressed, this standard would be fully met. Risk assessments in relation to health care and personal care needs including mobility are maintained. This is so that potential risks are identified, minimised and managed so that residents are not put at risk. Wherever possible, people moving into the home do have a choice of rooms, and are encouraged to add their own personal touches, either by the color scheme or with personal effects and items from their home. Staff said that they have all received training on medication. The records for the administration and management of medicines are kept in good order. Information from residents and medicine record charts show that medicines are administered as prescribed. Unused medication is returned to the dispensing chemist. Regular audit of the system including the ordering, storage, administration and disposal of medicines is carried out. Residents are registered with a GP from three local practices. Other professionals, residents have access to include district nurse, dentist, optician, podiatrist, dietitian and two hair dressers. Residents and relatives spoken with expressed a high level of satisfaction in the manner staff meet their needs. Examples include staff are very caring, Very supportive and Extremely helpful. Residents reported that their needs are being met in a professional way. Care Homes for Older People Page 13 of 27 Daily life and social activities These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: Each person is treated as an individual and the care home is responsive to his or her race, culture, religion, age, disability, gender and sexual orientation. They are part of their local community. The care home supports people to follow personal interests and activities. People are able to keep in touch with family, friends and representatives. They are as independent as they can be, lead their chosen lifestyle and have the opportunity to make the most of their abilities. People have nutritious and attractive meals and snacks, at a time and place to suit them. There are no additional outcomes. This is what people staying in this care home experience: Judgement: People using this service experience excellent quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. Varied activities are available for those who wish to participate, which may include friends and families, and food offered is of good quality with choice and variety available. Evidence: Evidence shows that staff facilitate a range of activities to suit residents needs. Five residents and two visiting relatives spoken with expressed a great deal of satisfaction regarding recreational activities being offered. Examples of comments include Always something taking place that I enjoy, Activities are available but I prefer to spend my time making Christmas and birthday cards, I enjoy reading books, I love knitting and various board games and I enjoy my chats with staff and like seeing my visitors. The home owns two mini-buses and this is seen as an excellent resource to access various activities in the community The care plans for three residents demonstrate that residents are being assisted to follow the lifestyle of their choice as discussed and agreed at the time of their assessments. All five residents spoken with said they are very satisfied with their lifestyle at Claremont House. Care Homes for Older People Page 14 of 27 Evidence: Evidence shows that family and friends visit regularly and they are always made welcome. Resident are able to entertain their visitors in the communal areas or the privacy of their own bedroom. Residents are encouraged and they are able to practice their religion and their culture, as they wish. The local vicar and priest visit regularly and offer communion and service. The menu seen provided for a nutritious and varied diet. The lounge/diner is well decorated and staff work very hard to make meal time a socially enjoyable occasion. Residents are able to take their meal in their own room, if they so wish. Residents are consulted regularly regarding the menu and their taste and preference. Meeting with the main cook indicates that alternative meals are provided if a resident does not like the meals on the menu. All residents, bar one, commented highly on the quality and variety of food offered to them. Examples include: Excellent food, Good food, We have fish on Fridays and Food, really good normally. One resident would like More chicken and fish and the manager has said that this would be addressed. The cook echoed confidence that dietary needs of the individual resident are well catered for. Care Homes for Older People Page 15 of 27 Complaints and protection These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: If people have concerns with their care, they or people close to them know how to complain. Any concern is looked into and action taken to put things right. The care home safeguards people from abuse and neglect and takes action to follow up any allegations. People’s legal rights are protected, including being able to vote in elections. This is what people staying in this care home experience: Judgement: People using this service experience good quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. People using this service can be confident that they will be kept safe by the homes procedures around safe working practices. Evidence: The AQAA tells us Complaints procedure on wall in entrance hall and in service users guide and statement of purpose specifying how/who to complain to with a response time limit. Record kept of all complaints and outcomes. All staff trained in sova and are monitored on knowledge and understanding. The home has written policies on complaints, Safeguarding of Vulnerable Adults and Whistle Blowing. Staff interviewed demonstrated an understanding of the above matters. Information on how to make a complaint is displayed on a notice board in the lobby area. Details of this is also included in the service users guide. Residents indicated that they know how to make their concerns known to staff, if they were worried about anything. No complaints at all, I am very happy with the service and I am sure staff would respond quickly to sort any problem I may have are typical responses from residents. The complaints record was viewed and there were no complaints recorded since the last annual service review in December 2008. The manager confirmed this to be accurate. Care Homes for Older People Page 16 of 27 Evidence: Staff spoken to said that they have received training in Safeguarding of Vulnerable Adults and the home follows the Bedfordshire County Council procedure on Safeguarding Adults. The manager reported that there have been no adult protection matter in the past year. Care Homes for Older People Page 17 of 27 Environment These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: People stay in a safe and well-maintained home that is homely, clean, pleasant and hygienic. People stay in a home that has enough space and facilities for them to lead the life they choose and to meet their needs. The home makes sure they have the right specialist equipment that encourages and promotes their independence. Their room feels like their own, it is comfortable and they feel safe when they use it. This is what people staying in this care home experience: Judgement: People using this service experience excellent quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. The accommodation is homely, well maintained and furnished to a high standard. A high standard of hygiene was evident. Evidence: We undertook a brief tour of the premises. The decoration and furniture and fittings in the lounge/diner, and eight bedrooms viewed are of a high standard. Bedrooms are well personalised to suit the taste of the occupants. Residents indicated that they are very happy with their bedrooms and that they are able to bring their personal possession and belongings. There is more than adequate space for residents to sit quietly and or meet with their family and friends. All first floor bedrooms have wash basin, toilet/bathroom or shower en-suite facilities and the ground floor bedrooms have wash basin and toilet en-suite facilities. The ground floor also benefits from a communal bathroom and a toilet for residents use. Suitable specialist equipment is available and serviced regularly. The home is well maintained. All areas viewed were noted to be very clean, tidy and free of odors. Staff were observed to wear suitable protective clothing when carrying out certain activities. Domestic and clinical waste is disposed of in an appropriate manner. There were no health hazards noted. Care Homes for Older People Page 18 of 27 Evidence: Residents spoken with expressed a high level of satisfaction in respect of their physical environment. My room is large and well furnished, I am only too happy to be here, said a resident. Care Homes for Older People Page 19 of 27 Staffing These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: People have safe and appropriate support as there are enough competent staff on duty at all times. They have confidence in the staff at the home because checks have been done to make sure that they are suitable to care for them. Their needs are met and they are cared for by staff who get the relevant training and support from their managers. There are no additional outcomes. This is what people staying in this care home experience: Judgement: People using this service experience good quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. Residents benefit from the care and support provided by a competent and qualified staff team; their protection is assured by the robust staffs recruitment process in place. Evidence: The AQAA indicates Full rota in place with skill mix and level of staff on duty to cover busy times. The service is currently fully staffed; as well as the manager and deputy manager, there are both full and part time staff to ensure that the needs of people living at Claremont House are met. There is a minimum of three care staff including a senior member available at all times during the day shifts and 2 waking members, on each night. Staff are always available, if you ask me, said one resident. There have been no major changes within the staff team recently and any annual leave or unexpected absences is covered internally, which ensures consistency and continuity of service. Recruitment policy and procedure is robust. The recruitment files for the three staff members interviewed were examined during the visit. They indicate that the necessary checks and information are all in place, including application forms, two written references, Criminal Records Bureau and Protection of Vulnerable Adults checks, training records and health declarations. However, a current photograph was Care Homes for Older People Page 20 of 27 Evidence: not available in any of the files; the manager said that this would be actioned as soon as possible. During the past year all the required mandatory training has taken place, and again this is evidenced in the files examined. Other more specific training completed includes Dementia Awareness, Medication and Safeguarding of Vulnerable Adults. The manager must ensure that all staff receive training in the Mental Capacity Act and how it affects their work, so that they are able to comply with it. Ten of the fifteen care staff including seniors have completed their NVQ level 2 or 3 training and another two members are currently doing the same course. On completion, a very good ratio (79.9 ) of staff would have this qualification ,which means that staff are being equipped with the appropriate skills and knowledge to deliver an improved quality of service to residents. We receive good training, you know, said two staff members. Care Homes for Older People Page 21 of 27 Management and administration These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: People have confidence in the care home because it is led and managed appropriately. People control their own money and choose how they spend it. If they or someone close to them cannot manage their money, it is managed by the care home in their best interests. The environment is safe for people and staff because appropriate health and safety practices are carried out. People get the right support from the care home because the manager runs it appropriately with an open approach that makes them feel valued and respected. The people staying at the home are safeguarded because it follows clear financial and accounting procedures, keeps records appropriately and ensures their staff understand the way things should be done. They get the right care because the staff are supervised and supported by their managers. This is what people staying in this care home experience: Judgement: People using this service experience good quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. Residents can be assured that their health, safety and welfare are protected and promoted by the safe practices in place and the support they receive from an experienced staff team. Evidence: The registered owner/manager is responsible for the administration/management of the home. He holds the Registered Managers Award since 2002. He has completed all mandatory training. He clearly has the knowledge, experience and skills to run a home for older people. He is well supported by the deputy manager and two senior care staff. Residents interests are always placed at the heart of decisions made. This was clear from documentation seen during the inspection and from discussions with residents. An annual quality assurance check ensures that the views of the people accommodated, as well as their relatives and professionals are taken into account. Care Homes for Older People Page 22 of 27 Evidence: Staff and residents told us that the manager and deputy manager are very helpful. Comments include Very supportive management team, The communication between staff and management is good and They create such a warm and friendly atmosphere and we like this. Records viewed are kept in good order. Staff are not involved in the management of residents financial affairs. However, a small amount of money is retained on behalf of twelve residents for their day today expenses. The administrative records examined for two residents indicate that any expenditure is accurately recorded. Health and safety policy and procedures are in place to ensure that the people either living or working in the home are not placed at risk. Evidence shows that regular maintenance checks are undertaken and any shortcomings identified, are speedily addressed. Care Homes for Older People Page 23 of 27 Are there any outstanding requirements from the last inspection? Yes £ No R Outstanding statutory requirements These are requirements that were set at the previous inspection, but have still not been met. They say what the registered person had to do to meet the Care Standards Act 2000, Care Homes Regulations 2001 and the National Minimum Standards. No. Standard Regulation Requirement Timescale for action Care Homes for Older People Page 24 of 27 Requirements and recommendations from this inspection: Immediate requirements: These are immediate requirements that were set on the day we visited this care home. The registered person had to meet these within 48 hours. No. Standard Regulation Requirement Timescale for action Statutory requirements These requirements set out what the registered person must do to meet the Care Standards Act 2000, Care Homes Regulations 2001 and the National Minimum Standards. The registered person(s) must do this within the timescales we have set. No. Standard Regulation Requirement Timescale for action 1 29 24 A current photograph of the staff must be available in their recruitment file as part of the proof of identity. This is to ensure the protection of residents. 31/12/2009 2 30 18 The manager must ensure that all staff receive training in the Mental Capacity Act and how it affects their work. This is so that they comply with it and ensure the protection of residents. 15/03/2010 Recommendations These recommendations are taken from the best practice described in the National Minimum Standards and the registered person(s) should consider them as a way of improving their service. No Refer to Standard Good Practice Recommendations 1 7 The monthly review notes should be rationalised, recorded and retained in one place; this would offer a holistic overview to enable the manager take remedial action where required. Care Homes for Older People Page 25 of 27 Recommendations These recommendations are taken from the best practice described in the National Minimum Standards and the registered person(s) should consider them as a way of improving their service. No Refer to Standard Good Practice Recommendations 2 7 Monthly review notes should reflect the full name and signature of the staff member undertaking the monthly review, at all times. Care Homes for Older People Page 26 of 27 Helpline: Telephone: 03000 616161 Email: enquiries@cqc.org.uk Web: www.cqc.org.uk We want people to be able to access this information. If you would like a summary in a different format or language please contact our helpline or go to our website. 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