- Children, Schools and Families Committee Contents


Memorandum submitted by the Office for Standards in Education, Children's Services and Skills (Ofsted)

SUMMARY

  1.  Schools have been held to account through inspection for over 150 years, and there continues to be widespread public and professional support for clearly reported evaluations of their performance.

2.  Independent inspection, by an external inspectorate that has a clear national perspective and resulting in a published report, in which direct observation of the school at work plays a significant role, has a key part to play in assuring accountability.

3.  Good self-evaluation by schools, verified by external and independent inspection, is crucial.

  4.  Teachers and parents alike agree that school inspection is beneficial and promotes improvement.

  5.  A very large majority of headteachers say that school inspections are accurate, productive, identify the right issues and provide recommendations that are helpful in moving the school forwards.

  6.  Inspections rightly focus on the achievement and attainment of learners, although all five Every Child Matters outcomes are also evaluated. However, there is an opportunity to further develop the emphasis on these other outcomes, to improve the ways in which schools are held to account for their contribution to them, and how they are reported to stakeholders.

  7.  There is a need for external inspection because schools are organic, constantly changing organisations, so there is always a small risk of some becoming inadequate. Additionally, inspection has been a significant lever in driving the improvement of schools over the last 20 years and continues to do so as national expectations rise.

ACCOUNTABILITY

Is it right in principle that schools should be held publicly accountable for their performance?

  8.  Maintained schools should be held publicly accountable for their performance. As publicly funded institutions, they are responsible for the outcomes for children and young people, including their standards of attainment, progress, personal development and well-being. Independent providers should also be held accountable for meeting government regulations.

9.  School self-evaluation can be a powerful driver for improvement, particularly when aligned with inspection and public accountability.

What should be the fundamental purposes of an accountability system for schools and, in particular:

 (a)   to whom should schools be accountable?

10.  Schools should be accountable to users; in particular learners, parents/carers, and the local community, so that leaders can be held responsible for their policies and stakeholders can assess the value of the service. There is a legitimate national interest in the welfare and education of all children, in all schools and settings. Schools should be held to account at local level by the appropriate authority, which is nationally accountable for local outcomes, and also to the taxpayer for making good use of funds provided.

 (b)   for what should they be held accountable

11.  Maintained schools should be accountable for the educational and well-being outcomes for the children and young people for whom they are responsible. These are summarised under the five ECM headings:

    — being healthy;

    — staying safe;

    — enjoying and achieving, including attainment;

    — making a positive contribution; and

    — achieving economic and social well-being, and spiritual, moral, social and cultural development.

  12.  Schools should be held accountable for the value for money they provide. Independent schools should meet the government's regulations.

 (c)   how should they be held to account?

  13.  Although there should also be local accountability, external inspection is the key method for holding schools to public account and parents are overwhelmingly in favour of inspection. The September 2008 survey of parents by Ipsos Mori found that only 4% were against inspection whereas 92% were in favour. This exactly mirrors the findings of the 2006 Ipsos Mori survey. Ofsted inspection provides an objective and independent evaluation, by a national body, working to an agreed framework and with no direct interest in the outcomes. Inspection includes evidence from direct observation, and takes into account qualitative and quantitative measures including the views of learners and other users.

 (d)   what should be the consequences?

14.  Reports about the quality and standard of the institution should be published. Where there are weaknesses, proportionate intervention should follow and focus on improving the quality and efficiency of services. Public accountability should ensure equality of opportunity for learners and provide assurance that schools meet the needs of individuals and society as a whole. Independent providers that do not meet statutory requirements should also be publicly held to account.

How do other countries hold their schools accountable for their performance and against what criteria?

15.  Within Europe models for school accountability fit three broad types. Firstly, in the majority of countries, authorities such as inspectorates are responsible for independently evaluating schools. Inspectorates vary in their degree of independence from government. Inspection systems may be centralised or devolved to local government. The Netherlands approach is similar to that of England, using school self-evaluation and a risk-based approach to inspection. Inspections range from a one day annual assessment to a full inspection according to a set framework, with published reports. The inspectorate may also conduct "quality improvement inspections" where there are concerns about a school's performance or may initiate an inspection in response to external factors such as media reports or complaints.

16.  In the second type, for example in Hungary and Norway, schools are accountable mainly to local authorities. In Norway, all schools have to evaluate pupils' results and progress, as well as their learning environments. The Regional Education Offices present to the Ministry annual reports based on statistical data, qualitative reporting and meetings with the education authorities in the municipalities and counties.

  17.  Other countries remain at the periphery of school inspection. Although schools are not inspected, they may be encouraged to perform self-evaluations, as in Italy.

  18.  Examination results are also used to hold schools accountable. In Hungary standardised tests, together with inspections, are used to evaluate schools. In Denmark the Danish Evaluation Institute carries out evaluations based on samples of schools. In the United States, under No Child Left Behind, there is a federal legislative requirement that schools must meet performance targets and make "adequate yearly progress"—measured by student achievement in tests, although the definition of this progress is decided by individual states.

Is the current accountability system of inspection and performance reporting for schools broadly fit for purpose?

  19.  We believe that the inspection system is fit for purpose, but as requirements change there is room to make it even better.

20.  Ofsted's role in the present system is to inspect and regulate efficiently to promote excellence in schools; in 2007-08, we spent only £46 million on routine school inspection, yet our reports have a high public presence with a daily average of 14,437 viewings of reports on our website.[1] Inspections provide evidence about provision and outcomes in individual institutions. Ofsted also carries out inspections which focus on different aspects of provision; these give a national picture of strengths and weaknesses, for example in subjects and curriculum areas, and inform Ofsted's advice to the Secretary of State. They provide the basis for Ofsted to disseminate findings, including good practice, and to give institutions feedback to promote improvement.

  21.  Through the post-inspection online survey, the School Inspection Survey (SIS), we know that almost all respondent headteachers are positive about the inspection process. Of 4,229 responses in 2007-08:

    — 92% believed judgements about their schools were fair and accurate;

    — 96% intended to use the inspection recommendations to move their schools forward;

    — 96% agreed that inspection identified the right issues for improvement; and

    — 82% believed the benefits of inspection outweigh the negatives.

  22.  The outcomes of the SIS are consistent with an external evaluation of school inspection published in 2007 by the NFER.[2] This found that the vast majority (84%) of stakeholders thought the written report helpful in identifying areas for improvement and approximately three-quarters found it accurate in identifying strengths and weaknesses. This research provided evidence that the inspection system contributes to improvement, reporting that "the majority of survey respondents (87%) and case-study schools (around two-thirds) reported that action had been initiated on the recommendations. Furthermore, follow-up interviews showed that almost all case-study schools were implementing all or most of their recommendations."

  23.  The current system has been successful in helping promote improvement; the proportion of good and outstanding schools has increased from 59% in 2005-06 to 64% in 2007-08.

  24.  In a recent survey of teachers' views, due to be published in February 2009, NFER also found that 85% of teachers thought inspections identified new areas of priority for their schools, while 86% regarded classroom observations as an important and welcome aspect of inspection.

  25.  Over time, Ofsted has emphasised the importance of self-evaluation as the basis for school improvement and has made it central to the inspection process. In parallel, there has been a clear improvement in the quality of school self-evaluation and the proportion judged good or outstanding has risen from 65% in 2005-06 to 72% in 2007-08.

  26.  The system also includes performance reporting through the Achievement and Attainment Tables by the DCSF; these provide detailed, annual information about which parents and carers value, although they have become increasingly complex.

How should schools be held accountable for their performance in the context of increasing collaboration in education provision?

  27.  Schools' partnerships should be taken into account. Ofsted is working with the DCSF to refine ways of evaluating partnerships more securely within the accountability framework, for example by inspecting members of key partnerships at the same time; by carrying out survey inspections to evaluate the effectiveness of specific partnerships such as 14-19 diploma consortia; and by strengthening the evaluation of the impact of partnership work on the achievement and well-being of pupils. Common principles are being developed which will enable inspectors to evaluate the impact of collaborative working in schools, early years' settings and colleges.

INSPECTION

Is an independent inspectorate an appropriate mechanism for holding schools to account?

  28.  We believe that it is an important part of the overall accountability framework. Independent inspectorates should be responsible for providing information to users. Only independent national inspectorates can be sufficiently separate from local or national government to comment fearlessly on findings, but they should be appropriately accountable to Parliament.[3] Public confidence requires the inspectorate to be demonstrably independent and they must be economically and contextually free of association with the providers they inspect.

What is the impact of the inspection process on school performance, including confidence, creativity and innovation?

29.  Evaluations such as that by NFER (see Q6) indicate that inspections have a significant impact on performance, especially on the weakest schools. The study reported that "Amongst grade 4 schools, 95% reported taking action on Ofsted recommendations." Such schools report rapid improvement and even "satisfactory" schools have frequently responded to the inspection challenge by making improvements to leadership and management, teaching and assessment. Improved outcomes were apparent to the researchers, especially in primary schools. The 2007 NFER report also noted that good schools gained in confidence from the success of their inspection.

30.  The main impact of inspection, identified consistently in independent surveys by organisations such as Ipsos Mori and NFER, is improved teaching and leadership and more secure monitoring and evaluation of pupils' progress. The NFER teacher voice survey, 2008, showed clearly that 85% of teachers believed inspection had stimulated changes in teaching and learning and 88% believed it had led to new priorities being set. Headteachers also identify teaching as an area in which inspection has significant impact.

31.  The Ipsos Mori parent survey (2008) showed that 82% of parents also believe that inspection contributes to school improvement, and only 5% are sceptical about its impact.

  32.  Survey work contributes to national policy and has identified strengths and weaknesses in schools' practice. Recent examples reported on mathematics, food, and pupils' personal, social and health education. The survey report Curriculum Innovation in Schools, October 2008, reported that school leaders often had to overcome resistance to curriculum change and an erroneous view that Ofsted "favoured" a specific model of curriculum delivery. In fact inspection judgements are determined much more by schools' impact on outcomes for learners rather than the style of curriculum delivery.

Are inspectors appropriately qualified and trained to carry out inspections, particularly in the light of the need to report against Every Child Matters (ECM) outcomes?

  33.  We believe this is the case because all HMI undergo a rigorous selection and training process. Additional inspectors are also trained and extensively mentored, including supervised participation in "live" inspection and grounding in ECM outcomes and safeguarding. No inspectors may undertake inspection activity without supervision until HMI have declared they fulfil requirements. Every inspector is required to update their training to take account of any new inspection requirements. HMI lead many of the most complex inspections including 75% of secondary schools and 85% of schools causing concern. Inspectors are subject to rigorous performance management assessment and those whose performance is called into doubt are subject to tailored development programmes.

34.  The new inspection arrangements for September 2009 contain updated clear, detailed guidance to enable inspectors to evaluate ECM outcomes effectively.

Is it appropriate for inspection reports to be placed in the public domain?

  35.  It is in the public interest for all school reports to be rapidly and openly published to promote school improvement, enhance parental choice, and to provide public information. Publication is a key element of accountability processes except for when the privacy or security of young people would be compromised. Published reports are very popular with users: there were nearly 2.1 million viewings of reports on the Ofsted website between 1 September 2008 and 21 January 2009, with the reports viewed more than 50 times for 15,989 institutions.

How often should inspections be carried out and how long and detailed should these inspections be?

36.  It is important that parents/carers and others have regular information about the effectiveness of schools. Currently, in order to achieve this, schools are normally inspected once in a three-year period. In order to maximise the impact of finite resources, Ofsted is considering whether future inspections should be more targeted at those schools most needing improvement, and is proposing that, from September 2009, the best schools should be inspected once within five years. Ofsted proposes to publish a health check report for the good and outstanding schools whose inspections are deferred so that up-to-date information is available.

37.  Inspection needs to involve sufficient first-hand observation to command the confidence of the school and enable inspectors to provide an accurate, rigorous analysis and diagnosis of its effectiveness. However, it should not place more demands on the school than are necessary. Neither should routine inspections be as onerous as they were before 2005. The quality and standard of particular subjects can be evaluated and reported on through Ofsted's thematic surveys.

How much notice, if any, should a school receive of an upcoming inspection?

  38.  Notice periods should be short. Since September 2005 maintained schools have been notified two working days prior to a planned inspection. Schools are broadly positive about this and a survey of parents (November 2008) indicated that almost all those surveyed believed the current notice was adequate. However, 65% of parents that responded to Ofsted's consultation would welcome an even shorter notice period.

39.  Shorter notice periods have been found to reduce the stress of over-preparation. They also ensure inspectors see the "real school" and Ofsted is now piloting unannounced inspections of some maintained schools. Unannounced inspections may already be carried out if HMCI has concerns about the welfare of children.

  40.  Notice periods for all types of schools should be consistent. Currently, independent school inspectorates give a longer notice period than Ofsted.

In the context of an inspection, what is the value of:

    the school's self-assessment;the results of national tests; and

    the school's contextual value added scores;

and how much weight should be attached to these elements in the inspection report?

  41.  The school's self-assessment engages staff and governors in assessing the quality of school provision and its outcomes. In summarising the school's strengths and areas for development, it is an invaluable starting point for inspection, signposting areas for investigation, and providing a basis for inspectors to evaluate the school's capacity to improve. By focusing on school self-evaluation, inspection has helped schools to understand what they need to do to improve.

42.  National test data are valuable in inspection since they provide clear and standardised benchmarks of the standards attained by learners, against which their progress can be measured. Contextual value added (CVA) scores, alongside other data, provide invaluable information about the progress that individual learners make over time. They contribute significantly to evaluating a school's impact on learning when set alongside other more recent evidence. However, test and examination data and CVA information must always be compared with a range of other evidence including direct observation of lessons (and other parts of the school day), school self evaluations and other material, discussions with a wide range of staff and learners, evidence of parents' views and more recent school assessments in order to reach an holistic picture of the school's performance. Schools no longer feel that inspectors are over-reliant on data.[4]

In an inspection, how should emphasis be balanced between educational attainment and other aspects of a school's provision, such as the Every Child Matters outcomes?

  43.  The current inspection framework for maintained schools distinguishes between "standards of attainment" and the progress that learners make, given their capabilities and starting points. Most emphasis is given to pupils' progress rather than to attainment when judging how well "pupils achieve". The "other" ECM outcomes are considered separately as part of the pupils' personal development.

44.  From September 2009, it is proposed that there is a change in the balance between attainment, pupils' progress and the quality of learning, and that attainment receives more emphasis than currently when inspectors judge how well "pupils achieve and enjoy". This judgement remains key in evaluating a school's performance but great importance will be attached to the other ECM outcomes as well. For example, schools will not be judged "good" overall unless pupils' achievement, behaviour, the extent to which they feel safe, and at least one other outcome are good, with none inadequate.

Should inspections be tailored to the current performance levels of the specific school being inspected and, if so, to what extent?

  45.  Inspection frequency should directly relate to the performance of the school.

46.  Ofsted is proposing that from September 2009, the most successful schools should be inspected less frequently than currently. Sophisticated risk assessments which draw for example, on performance measures, previous inspection judgments and parents' and pupils' views, will be used to check that it remains appropriate to defer the inspection of these schools. The risk assessment process will provide an indication of the school's direction of travel—whether it is improving, static or declining.

  47.  There are no plans to reduce inspection frequency for satisfactory or inadequate schools. Satisfactory schools will continue to receive an institutional inspection after three years and those that show no signs of clear improvement will be scheduled for early inspection. Inadequate schools will continue to receive intensive monitoring.

Has the introduction of a light-touch inspection regime for higher-performing schools been appropriate?

  48.  Ofsted began the piloting of light touch inspections (named "reduced tariff inspection") in 2006. They were appropriate in reducing the tariff for the best performers, and have been effective. Our next plan, though, is to visit the best schools less frequently; we will devote more inspection time to the observation of teaching and the learning of pupils in order to further promote improvement, especially in schools which have not improved sufficiently. We can do this because we are providing the Health Check.

49.  Maintained schools are currently selected for a "light touch" on the basis of a risk assessment. In over 90% of schools which have received a light inspection the final grade justifies the selection. The School Inspection Survey completed by schools after their inspection shows that these inspections are equally valued by school leaders, as standard inspections. In 2007-08, 96% of headteachers were satisfied that their light touch inspection was well managed, that its findings were correct and that it would help their school improve, compared to 93% in standard tariff inspections.

What are the mechanisms for identifying schools which are underperforming and are those mechanisms adequate?

  50.  Schools which underperform are likely to be judged inadequate during routine section 5 inspections. Inspectors use published inspection guidance, clear criteria and detailed, sophisticated data which inform, but do not dictate, their judgements. Their judgements are made on the basis of a range of evidence, including direct observations in lessons. Most schools in Special Measures recover within two years, but others may be closed or formed into federations.

51.  In future, where performance data indicate signs of deterioration, a school may be selected for an early inspection. Additionally, Ofsted has the power to respond to both complaints and local authorities' warning notices by inspecting the schools concerned.

How effective has the classification of "schools causing concern" (special measures or improvement notice) been in supporting improved performance in the schools concerned?

  52.  Inspection evidence indicates that designating schools in "categories of concern" is often the first step in driving improved outcomes for pupils. It is a "wake up call" that has a positive impact on improving performance, the quality of teaching and learning and the effectiveness of leadership and management. It also triggers additional support and intervention from other agencies. In due course, sustained improvement means that standards also rise. Ofsted's Review of the Impact of Inspection (May 2007) concluded that "those providers judged to be inadequate make the greatest strides in improving provision after inspection."

53.  The designation of special measures galvanises necessary changes in leadership. Inspection evidence amply demonstrates that improvements in inadequate schools stem from strong and sustained leadership, which uses the recommendations from inspection and monitoring visits to eradicate the school's weaknesses. During 2007-08 the schools given notice to improve in 2006-07 were re-inspected; of these, nine in 10 had made at least satisfactory progress overall and 40 of these had become good schools. However, a very small minority had declined and were made subject to special measures. Of the 153 schools removed from special measures in 2007-08, 16% were judged to be already good schools.

  54.  The average length of time that schools spend in special measures has decreased significantly since 1997-98, reflecting the increasingly effective impact that designation and subsequent targeting of support have on transforming inadequate schools.

Have School Improvement Partners been of benefit to schools?

  55.  The School Improvement Partner (SIP) scheme is being considered as part of a rapid response survey in 2008. Ofsted is also currently undertaking a survey of the effectiveness of the National Strategies and is due to report later in the year.

56.  Evidence from current school inspections suggests that SIPs vary in the levels of challenge they offer and the contribution they make to school improvement.

Is the current procedure for complaints about inspections adequate?

  57.  As part of Ofsted's process of continuous improvement, procedures for handling complaints about inspections have recently been reviewed. As a result, revised procedures to improve complaints' handling will be introduced in September 2009. Complainants have recourse to the Independent Complaints Adjudicator if they are not satisfied with Ofsted's handling of their complaint.

PERFORMANCE REPORTING (OTHER THAN THE OFSTED INSPECTION REPORT)

What aspects of a school's performance should be measured and how?

  58.  A school's performance influences pupils' academic standards, how much they know and understand, their skills, and the progress they have made. These important aspects can be measured using data from national tests and examinations. It is also necessary to take account of the school's context and the prior attainment of pupils, in order to assess the value added by the school.

59.  Pupils' well-being and their personal development are less easy to measure, but nonetheless schools are accountable for their contribution to how well pupils and young people develop. There is little hard data at school level, and Ofsted and the DCSF propose to use information from surveys of pupils and parents as well.

60.  Aspects such as the effectiveness of teaching and learning and leadership, as well as compliance with selected statutory requirements and the extent to which the school commands the confidence of its stakeholders, are best measured through inspection. It is important that aspects such as teaching are inspected by an external inspectorate with a national perspective of what constitutes outstanding practice; when coupled with incisive feedback to teachers, this is also a powerful driver for improvement.

How should these performance measurements be reported and by whom?

  61.  Performance measurements should be reported in ways that maximise their accessibility to all stakeholders. Data relating to academic standards should be published centrally, by the DCSF. This will ensure consistent reporting for all schools, and enable comparison of the school's data against national comparators. If the data are reported in a table or report card, these should be simple in format so that they are easily understood.

62.  Some other performance measures, such as parental satisfaction, could helpfully be reported in a standard format by Ofsted or the DCSF. Reporting should be concise, unambiguous and accessible to pupils, parents, schools' staff, other stakeholders, government and the general public.

To whom should this information be made available?

  63.  Most data on schools' performance should be published and made available to the public. Most is, in any case, available under the Freedom of Information Act.

What is the effect of the current system of public performance reporting (Achievement and Attainment Tables www.dcsf.gov.uk/performancetables/, and the online School Profile schoolsfinder.direct.gov.uk) on a school's performance, including confidence, creativity and innovation?

64.  Performance tables reflect a narrow although important part of schools' work. Currently, the range of public information on schools' performance can be confusing and in practice, parents may rely more on Ofsted inspection reports than the Achievement and Attainment Tables, because the reports provide a more holistic evaluation of the school.

65.  The publication of information about schools' performance through test and examination results, can lead in some cases to teaching to the test and a narrowing of the curriculum in certain year groups. However, inspection evidence shows that the most successful schools avoid this by focusing appropriately on national assessments without reducing breadth in the curriculum.

What is the impact on schools of league tables published by the press?

  68.  Apart from the information reported above, Ofsted has no evidence for this.

How useful is this information to stakeholders, particularly parents?

69.  Ofsted has no data about the usefulness of performance tables to parents though parents have reported the difficulties they have in interpreting these. However, Ofsted's inspection reports are likely to be one of the main sources of information for parents choosing a school.

SCHOOL REPORT CARD

What might a school report card usefully provide that is not covered by the current performance reporting system?

  70.  In addition to Ofsted inspection reports, the current performance reporting system includes the Achievement and Attainment Tables, the School Profile, and schools' prospectuses.

71.  The Achievement and Attainment Tables are published annually, but the information can appear daunting for users, and gives only a partial picture of a school's performance. Profiles may be updated less frequently.

72.  Ofsted inspection reports provide a broader view of a school's effectiveness and an analysis and diagnosis of why a school's performance is as it is; however, most schools are only inspected once every three years and for good and outstanding schools the interval between inspections will soon be increased to five years. The school report card would complement Ofsted inspection reports by providing parents, at more frequent intervals, with a clear, comprehensive and accessible overview of a school's performance in certain areas.

Are there any issues which the school report card should avoid or seek to inhibit?

  73.  A range of issues raised by the proposed introduction of a school report card are currently subject to consultation by the DCSF and Ofsted. In developing its view of these issues, Ofsted, with the DCSF, will take account of the outcomes of the consultation. Where data are reliable, no areas of a school's responsibilities should be avoided.

Is the school report card potentially a sound basis for:

    informing parents; providing a set of prioritised outcomes for schools;

    providing a starting point for Ofsted inspection; and

    providing a management tool for government?

  74.  The school report card, potentially, provides a sound basis for all the above.

  75.  It will establish a clear and agreed basis for providing information for parents through the published evaluation of schools' performance, in which the relative priority accorded to different outcomes is clearly and consistently defined.

  76.  The indicators that underpin the school report card will be aligned with the core of the inspection assessment process undertaken by Ofsted to inform the selection of schools for inspection, although the latter is likely to use additional information. As a result, there will often be a clear connection between a school's performance as shown in its report card and the timing of its next inspection.

  77.  As a management tool for government, the school report card could prove much more effective than the Achievement and Attainment Tables, because it reflects the wider range of outcomes that 21st-century schools should seek to achieve, with the relative priority accorded to each clearly indicated. However, only inspection can provide an holistic evaluation of the school, including the evaluation of teaching and learning based on observation.

Could the school report card appropriately replace some Ofsted reporting?

  78.  Ofsted has proposed in consultation that schools which are likely, on the basis of its assessment, to be judged good or outstanding when inspected, should have a longer interval between their inspections and receive a "health check report" rather than an inspection three years after their previous visit. We believe that the introduction of the School Report Card will make a separate health check report by Ofsted unnecessary, but it can never replace the direct observation of a school at work. The two approaches are complementary: Ofsted reports do not include tables of data, and the Report Card will not be able to explain why schools are as they are or describe teaching. Inspections draw on much wider evidence including the views of learners, parents and staff as well as the direct observation of lessons and breaktimes; they are able to probe areas for improvement in ways which the simple reporting of data cannot. The report card could not, for example, describe behaviour or a school's work to promote equalities. Only inspection can provide the diagnosis of why a school is like it is which is necessary to plan or sustain improvement.

January 2009









1   During the period 1 September to 21 January 2009, 2,079,038 viewings of reports were made at an average of 54 per institution. Back

2   NFER is currently engaged in a further evaluation of school inspection; publication is expected in spring 2009. Back

3   Note that there are three other "independent" inspectorates which are authorised by DCSF to inspect sectors of independent schools. We have not considered the role of these here. Back

4   1,900 inspections were conducted during the last three month period; in all of these, there was only one inspection in which a complaint about the use of data was upheld. Back


 
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