Child Protection Improvement Programme

Child Protection Improvement Programme Update #17

December 18, 2020 by No Comments | Category Uncategorized

The National Child Protection Leadership Group

The National Child Protection Leadership Group is scheduled to meet on 11 December 2020. The agenda will include updates on the National Child Protection Guidance consultation, the Learning Review guidance, the public protection induction for Chief Officers, and Joint Investigative Interviews (JII) and Barnahus.

Revision of the National Child Protection Guidance

The Scottish Government consultation opened on 21 October and will close on 17 January 2021. A consultation engagement event for CPC Scotland was held on 16 November, and a further 6 events are being run for CPC members.  The revised National Guidance for Child Protection in Scotland is due to be published in Spring 2021.

You can read the draft National Guidance and respond to the consultation here:

The development of practice notes, and work on the participation of children, young people and families continues.

COVID-19 Supplementary National Child Protection Guidance was developed for Chief Officers, Chief Social Work Officers and Child Protection Committees. This was first published on 31 March 2020 and was last updated on 31 August 2020. The supplementary guidance will be updated further as necessary.

Case Review Oversight Group – (Significant Case Reviews)

The Case Review Oversight Group was established in May 2019.  This Group is chaired by Alan Small and is co-ordinating CPIP/System Review recommendations relating to Significant Case Reviews and  considering the purpose, criteria and governance of such reviews. The work of the Group is nearing completion and the draft Learning Review Guidance has been shared with CPCScotland. The Group will make recommendations to the Child Protection Leadership Group in early 2021 on a proportionate and timely approach to reviews that supports a learning culture and also the successful implementation of findings to support improvement in child protection practice.

Expert Group on Preventing Sexual Offending involving children and young people

The Scottish Government continues its considerations regarding action to address the recommendations made by the Expert Group on Preventing Sexual Offending involving Children and Young People.

Ongoing research by the Children and Young People’s Centre for Justice (CYCJ), funded by the Scottish Government, to explore potential links between childhood experiences and harmful sexual behaviour using data from the Intervention for Vulnerable Youth (IVY) project is due to complete before the end of 2020.

As part of Young Scot’s DigiKnow campaign, a survey to seek the views of young people on online harmful sexual behaviour is planned to launch in December 2020. The survey, co-designed by young people, follows on from the survey on online sexual attitudes carried out by the Expert Group in 2019.

Implementing the Children’s aspects of the Human Trafficking and Exploitation (Scotland) Act 2015

As part of the Home Office National Referral Mechanism (NRM) Transformation Programme, the Home Office have been considering an alternative model for the decision-making process of the National Referral Mechanism for child victims of trafficking,  and are now looking to pilot the model in select local authorities which are responsible for children’s social care. The aim of the pilots is to test whether determining if a child is a victim of trafficking within existing child protection structures can provide better alignment with the provision of local, needs-based support and any law enforcement response. Scottish Government is currently working with the Home Office and stakeholders on how this would work in Scottish context.

On 02 November, the Home Office launched a competitive bid for local authorities across the UK to apply to be part of the pilot. This bid recently closed and we are awaiting next steps.

Unaccompanied Children in Scotland

On 24th September, the Scottish Guardianship Service celebrated a decade of supporting unaccompanied and trafficked young people in Scotland. Part of the celebrations included a 10th birthday party which the Cabinet Secretary for Local Government and Communities attended. More information about the service and the work the service has done over the last decade can be found here:

To mark the 10th anniversary of the Scottish Guardianship Service a parliamentary members’ business debate took place on 04 November 2020. The Minister of Children and Young People closed the debate and reiterated the Scottish Government’s commitment to the Scottish Guardianship Service and ensuring unaccompanied asylum seeking children are welcomed and supported so that they can thrive in Scotland. A copy of the debate transcript can be found here:

National Transfer Scheme Consultation

Last month, the Home Office consulted on their proposals to improve the National Transfer Scheme (NTS). The consultation closed on 30 September 2020, and we are awaiting an update on the next steps.


The Scottish Government is exploring the application of the Barnahus concept for immediate trauma informed support for child victims of serious and traumatic crimes within the context of Scotland’s healthcare, child protection and criminal justice systems and to explore how Barnahus could work. Barnahus provides Scotland with an opportunity to design a genuinely child-centred approach to delivering justice, care and recovery for children who have experienced trauma, including, but not only, child sexual abuse.

Healthcare Improvement Scotland  (HIS) and the Care Inspectorate (CI) were commissioned by the Scottish Government to develop Scotland-specific standards for Barnahus based on the European PROMISE Quality Standards which are based on best practice from the Nordic countries.

The impact of Covid-19 resulted in the suspension of work on Barnahus Standards development whilst frontline services prioritised immediate responses to the pandemic.  We have agreed with Healthcare Improvement Scotland, the Care Inspectorate and key stakeholders that work will re-start in December under a revised timetable to build on learning from the current children and families, health and justice work-streams and the impact of and response to COVID-19 to support the continued co-design of draft standards for consultation in 2021.

Joint Investigative Interviews

The Scottish Government continues to fund and work with justice and social work agencies to improve the quality and process for Joint Investigative Interviews (JIIs) with vulnerable child witnesses, including the updating of national guidance and improving technology and facilities.

We are now in the second year of piloting activity in relation to the new model (the Scottish Child Interview Model) for joint investigative interviewing, which is both trauma informed and achieves best evidence through more robust planning and interview techniques. The new JII practice model launched in Lanarkshire on 10 February 2020 and in North Strathclyde on 10 August 2020.

The National JII Implementation Team has Identified the third pilot site and has begun working with Dumfries & Galloway to support them in preparing local conditions to support implementation and is currently working to agree the fourth pilot site.

Age of Criminal Responsibility (Scotland) Act 2019

Scottish Government officials continue to work with operational partners to develop guidance and processes for the use of police powers in the Act. This includes the development of a list of places of safety, guidance for use of the power to take a child under 12 to a place of safety, guidance and process for the investigative interview, and development of the role of child interview rights practitioner.

Part 2 of the Act (provisions relating to disclosure of convictions and other information) is due to be commenced at end-November 2020.

Children (Equal Protection from Assault) (Scotland) Act 2019

This Act removed the common law defence of “reasonable chastisement” from the law of Scotland, making all physical punishment of children unlawful on 7 November 2020.

The Act also requires the Scottish Ministers to take steps to promote public understanding and awareness about the removal of the reasonable chastisement defence. This obligation came into force on 8 November 2019.

The Scottish Government has published details about the Act, its background and where support can be obtained on a dedicated webpage.

The Scottish Government formed an Implementation Group which has worked on what is required to implement this legislation.  Information about the work of this group can be found on the Scottish Government’s website The Group will continue to meet so as to consider anything further required on implementation.

As part of its implementation work, the Scottish Government issued a letter and framework document on the Act to statutory bodies.  These documents are intended to inform a consistent approach to implementation of the Act across delivery bodies and they will be published on the Scottish Government website shortly.

Children’s Hearings System:

The first face to face children’s hearing since lockdown began took place on 15 July. Work is progressing on schedule to facilitate face to face hearings in every hearings centre nationwide, with modifications required in some centres to ensure the safety of attendees. Thanks to the extraordinary efforts from the responsible agencies, this marks a significant step on the road to system recovery.

The resumption of ‘Face-to-face’ children’s hearings  – where safe to do so – was included in Phase 1 announced on 21 May. Safety remains paramount, and no child, family member, volunteer, staff or professional will be called to physically attend a hearing unless the responsible agencies are satisfied that it is safe.

SCRA sent recovery proposals to Health Protection Scotland in mid-June and received detailed feedback. With the benefit of that advice, some SCRA staff returned to work in hearing centres – in Glasgow, Stirling, Edinburgh and Dundee – in the week commencing 22 June.

The inclusion of children’s hearings in phase one, in common with some other statutory tribunals and courts, is a reflection of our understanding that the work to achieve a safe recovery had to be started early. The children’s hearings system is vital to determining the rights and life chances of Scotland’s most vulnerable children. But service recovery is not straightforward.

The intrinsic informality of the hearings system and layout of hearings centres bring their own complexities to recovery planning. It was felt vital to move at pace to set in hand preparations for the resumption of face to face hearings at the earliest possible point.

We introduced extraordinary flexibility measures to support the system in April’s emergency Coronavirus (Scotland) Act 2020. The first report on the use of those powers was published on 9 June 2020. The Coronavirus Act provisions have allowed the system to focus on immediate or urgent protection – whilst keeping safe other children and young people whose situations are not currently urgent.

Virtual hearings have been in place across the country from 4 May, ensuring that the service has continued to operate to the fullest extent possible. Virtual hearings will continue to take place where necessary and appropriate during system recovery.

The Scottish Government is in regular dialogue with the children’s services sector and children’s hearings partners to monitor the impact of the pandemic on service provision and the protections afforded to children. We want to quickly apply the learning from how the system has coped in this crisis. We will want to hold on to good innovations. The ‘new normal’ must enable children’s hearings partners to ‘keep the promise’ we made to children and young people and the Independent Care Review.

The Scottish Government has made more than £2m available to support the swiftest possible system recovery and renewal. Recovery plans are in place for hearings to return to a steady state by autumn 2021.

The Supreme Court has heard arguments that siblings views should be considered at all stages when  a child is referred to a children’s hearing, with social work assessments of key family relationships being the starting point. The court has now decided that the children’s hearing system if operated sensibly is ECHR compliant. New provisions offering an opportunity to participate have been passed in the Children (Scotland) Act.

16/17 year olds within the Children’s Hearings System

In March 2017 the independently chaired Child Protection Systems Review submitted their report recommending the Scottish Government review measures available to protect 16 and 17 year olds.

The 2019-20 Programme for Government made a commitment to consult on ‘enabling joint reporting to the Crown Office and Procurator Fiscal Service and the Principal Reporter of all 16 and 17 year olds’ offence cases’.

Ministers agreed to widen the consultation to seek views on increasing the age at which children can be referred to the Reporter for care, protection and offence grounds.  This includes young people at risk of exploitation, abuse or harm due to their own behaviour or the behaviour of others. Proposed changes will enable agencies to provide child-centred support for all under 18 years old.

The consultation ran from June to October and an independent analysis was published on 7 December.

There was overwhelming support to raise the maximum age of referral to 18 for care, protection and offence cases, allowing equal opportunities for young people to get the right support at the right time.

We will now work with partners to identify the areas which require improvement and change, including legislation, whilst reflecting the Government’s commitment to UNCRC incorporation and the recommendations of The Promise.

National Review of Care Allowances

The National Review of Care Allowances reported in September 2018 and published 12 recommendations for improvement. The report can be read here:

The Scottish Government is committed to working with COSLA to agree how best to take forward the recommendations of the Review, with a view to implementation as soon as possible. This will improve consistency and transparency for looked‑after children, their families and their carers across Scotland.

The Promise

The Scottish Government remains fully committed to deliver on its pledge to care experienced people in Scotland by accepting and responding to the care review conclusions and to put into place quickly the infrastructure to develop and deliver an Action Plan to implement the outcomes reached and ‘#KeepThePromise’.

The 2020/21 Programme for Government illustrates our unwavering commitment to delivering The Promise, highlighting three early steps:

Firstly, we are committed to creating a structure that can facilitate the re‑design of whole system approaches to care and support. This begins with embedding the commitments that have already been made to care experienced people into policy and delivery, with significant and intensive work across the entirety of government policy;

Secondly, an Oversight Board is being established to hold us all to account, with Fiona Duncan – Chair of the Care Review – appointed to lead it. At least half of the members of the Oversight Board will be care experienced, because we cannot build a new approach without having those with lived experience at the heart of accountability. Recruitment for the oversight board commenced in October 2020;

Finally, we are also supporting the establishment of a dedicated, independent Promise Team, including investing £4 million in the Promise Partnership Fund that will help embed and scale‑up holistic family support. We will also support and develop the workforce so that they have the opportunity to keep The Promise.

Children (Scotland) Act

The Children (Scotland) Act gained Royal Assent on 1 October 2020.

The Act was informed by the outcome of a consultation on the Review of Part 1 of the Children (Scotland) Act 1995 (the 1995 Act). Part 1 of the 1995 Act covers parental responsibilities and rights and contact and residence cases relating to children when parents are no longer together.

The key policy aims of the Act are to:

  • Ensure that the child’s best interests are at the centre of any contact and residence case or Children’s Hearing;
  • Ensure that the views of the child are heard;
  • Ensure further compliance with the principles of the United Nations Convention on the Rights of the Child; and
  • Further protect victims of domestic abuse and their children in family court proceedings.

The Act covers a range of areas including:

  • Establishing a register of Child Welfare Reporters and curators ad litem;
  • Regulating child contact centres;
  • Encouraging the views of younger children to be heard by decision makers;
  • Protecting victims of domestic abuse by prohibiting personal contact of a case in certain circumstances and authorising special measures to be used in family court cases; and
  • Promoting of contact between looked after children and siblings.

We recognise that primary legislation is only part of the action necessary to improve the operation of family justice.  A Family Justice Modernisation Strategy was published on 3 September 2019. This sets out work that is ongoing by Scottish Government and others; work that can be done via secondary legislation or by improved guidance; areas covered by the Act; and areas that are for longer term work. It includes the PFG commitment to keep siblings together where it is in their best interests.

The Act will take time to implement as a number of the provisions require secondary legislation, changes to court rules or significant further consideration. We will look to commence sections of the Act as soon as possible.

UNCRC Incorporation Bill

A Bill to incorporate the UNCRC and Optional Protocols 1 and 2 to the maximum extent of the Scottish Parliament’s powers was introduced on the 1st of September 2020. The Bill will ensure that there is a proactive culture of everyday accountability for children’s rights across public services in Scotland.  This will mean that children, young people and their families will experience public bodies consistently acting to uphold the rights of all children in Scotland. It will mean that for the first time that children and young people, or their representatives, can enforce their rights in the courts. It is our intention that the Bill will result in the highest protection for children’s rights possible.

The Equalities and Human and Rights Committee issued its call for evidence on the Bill on 7 September 2020. This will close on 16 October to be followed by consideration of the Bill at Stage 1 shortly thereafter.

Children’s Rights and Participation

On 20th November 2020 we published our progress report on our Action Plan on Progressing the Human Rights of Children in Scotland 2018-21. The Report provides an update on the progress made in taking forward the strategic actions within the Action Plan since November 2019.

The 31 March 2020 marked the end of the initial reporting period for the duties placed on public authorities under Part 1 (section 2) of the Children and Young People (Scotland) Act 2014. The duty states that those public authorities, listed under Schedule 1, should report, “as soon as practicable” after the end of each 3 year period, on the steps they have taken to secure better or further effect within its areas of responsibility of the United Nations Convention on the Rights of the Child (UNCRC) requirements.

We are clear that promoting, protecting and fulfilling the rights of children has never been as important as it is now, in what will be worrying and confusing times for many.  We also realise that Covid-19 will be placing a significant burden on colleagues working in public authorities at this time in terms of both planning and delivery of public services and individual personal circumstances.

In light of this, Part 3 (duties in respect of reports and other documents), paragraph 8, of Schedule 6 (Functioning of Public Bodies) of the Coronavirus (Scotland) Act 2020, allows for Scottish Public Authorities to postpone publishing reports or laying reports before the Scottish Parliament if they are of the view that doing so is likely to impede their ability to take effective action to prevent, protect against, delay or otherwise control the incidence or transmission of coronavirus. These provisions were originally due to expire on 30 September 2020 but following approval from the Scottish Parliament, they have been extended until 31 March 2021. They can now only be extended one further time, to 30 September 2021 and cannot be extended longer than that. As of 18 November, we are aware of 4 public authorities who have, or are in the process of, publishing their report and a further 2 who have, or are in the process of, publishing a statement confirming a delay.

There are widespread concerns about the impact of  COVID-19 and the response to it on the rights of children and young people, including by the UN Committee on the Rights of the Child who published 11 recommendations for governments. The Scottish Government has produced four reports for Together (Scottish Alliance for Children’s Rights) on the action being taken in relation to these recommendations, and have committed to providing further updates.

Because children’s rights and wellbeing matter now more than ever, Scottish Government are embedding children’s rights into our response to Covid-19. Ministers have a clear expectation that Child Rights and Wellbeing Impact Assessments (CRWIAs) will be undertaken on all new policies and legislation.  A CRWIA was prepared and published for the Coronavirus (Scotland) Act, and we were commended for doing so.  A CRWIA has also been prepared and published for the Coronavirus (Scotland) (No. 2) Act, the Education (Miscellaneous Amendments) (Coronavirus) (Scotland) Regulations 2020, on the closure and reopening of schools as part of the COVID-19 recovery process in Scotland and the impact of restrictions on social gatherings on children and young people. CRWIAs are a practical tool enabling us to assess the likely impacts of intended actions on children’s rights and wellbeing and to put mitigations in place.

Equally Safe

Work is on-going across Government to ensure assess the impact of the crisis on victims and survivors of gender based violence and to help shape our response.

Our aim is that no change to the level of support, response, or help available is felt by victims of domestic abuse because of the Covid-19 crisis; but that it is adapted to fill their needs within the current climate. Over £1.5 million has been allocated to Scottish Women’s Aid, ASSIST and Rape Crisis Scotland to support this.

As co-owners of Equally Safe: Scotland’s Strategy to Prevent and Eradicate Violence Against Women and Girls, COSLA and the Scottish Government have developed supplementary guidance for local authorities and other key community planning partners to help them carry out the important work they do to support women and children affected all forms during the challenging times caused by Covid-19.

The Equally Safe Joint Strategic Board is co-chaired by the Minister for Older People and Equalities and COSLA Community Wellbeing Spokesperson, Cllr Kelly Parry. The most recent meeting of the Board was held virtually on 22 April 2020 and offered our key stakeholders and partners the opportunity to discuss our response to the crisis and identify areas we need to do more. We have now published the Equally Safe Year Two Report which was produced jointly with COSLA and the Improvement Service. The report can be viewed here.

Membership of the Equally Safe K-Hub group has grown steadily, and we continue to use the space to share resources and papers. Those with an interest are encouraged to join and share within your networks.

Female Genital Mutilation (FGM)

The Female Genital Mutilation (Protection and Guidance) Act was passed unanimously by the Scottish Parliament on 19 March 2020 and received Royal Assent in April.

Due to the pressing nature of some of the issues arising out of the Covid-19 pandemic and subsequent lockdown, this work was paused for several months. However, it is now resuming and officials are in the process of developing plans on what this will look like in the COVID-19 context.

We are continuing to implement Scotland’s national action plan to prevent and eradicate FGM, which was published in 2016. We published a Year 3 Progress Report on the Action Plan on the 8th of November 2019. You can view the report here.

Support to Disabled Children and Young People

We know that COVID-19 is disproportionately affecting some groups of children. Children and young people may have a pre-existing need for additional support or may develop a wellbeing need during the ongoing pandemic because of factors related to their personal development, features of their family life, or because of wider influences that impact on them within their community.

The Support to Disabled Children and Young People Team has recently been created within the Children and Families Directorate to consider wellbeing, planning, and support for disabled children and their families. The priority focus within this team is on facilitating greater co-ordination of the work across Government to improve disabled young people’s transitions from school into young adult life.

As part of our commitment to improving transitions for young people, the team has also been working in partnership with ARC (Association for Real Change) Scotland and the Children and Young People Improvement Collaborative (CYPIC) to develop and deliver the ‘Principles into Practice’ framework trial programme. Local Authorities and Health and Social Care Partnerships have recently been invited to submit expressions of interest in this trial. The purpose of the trial is to improve the transitions support available to young people and their parents and carers in the participating trial areas, and to test and bring the draft of Principles into Practice and associated resources to completion, in order to support its implementation more widely.

The Support to Disabled Children and Young People Team continues to provide secretariat support to the Disabled Children and Young People’s Advisory Group (DCYPAG). This group aims to promote best practice; to work in partnership with existing stakeholder groups, and to ensure that the voices and lived experiences of disabled children, young people and their families feature strongly in our policy.

DCYPAG has continued to meet regularly to share information on how the impact of the pandemic is affecting disabled children, young people and their families. Representatives from DCYPAG presented some of their key findings to the Covid-19 Children and Families Collective Leadership Group on 3 September 2020, which stimulated discussion on how to further collectively support this particular group of children, young people and their families as we move through and out of the crisis.

Scottish Government also offers secretariat support to the Disabled Children Child Protection Network. This is an independent network for practitioners who work with disabled children, young people and families and who have particular responsibility for, or interest in, child protection. The first newsletter for this was recently issued to members of the network.

On 19 August 2020 Scottish Government announced additional funding to enable the Family Fund Scotland to support an additional 560 families on low incomes raising disabled or seriously ill children and young people, by providing grants for items including tablets/computers, outdoor play equipment, sensory toys, and furniture to help make their lives easier.

We also continue to review and update the Scottish Government’s Supporting Disabled Children, Young People and their Families Information Website which provides families with information and advice on matters such as finance, housing, transitions, resources, support organisations, health and safety, online safety and education.

Getting it right for every child Update

The Scottish Government is updating Policy and Practice Guidance on Getting it right for every child (GIRFEC) to promote and support GIRFEC good practice. This will provide organisations and practitioners with confidence, clarity and practical support to deliver GIRFEC, underpinned by necessary, relevant and proportionate information sharing.  We will also develop information and guidance for children, young people, and parents.

This guidance will be developed in partnership with delivery partners and stakeholders including children, young people and parents.   Work had been progressing well, in partnership with key delivery partners but was paused as a result of COVID.  Implementing GIRFEC is essential to responding to, and recovering from, COVID and we are considering options for re-engaging with key delivery partners resuming work that was paused due to COVID.

Scottish Government has been engaging with local authorities to explore how they are working together with families, communities and third sector organisations to continue to provide children with the support they need.

Getting it right for every child Leadership Programme

Delivery of GIRFEC requires the services that support children to work collaboratively together to improve outcomes for the children and families that they are working with. Covid-19 has seen some excellent innovative practice being developed and we will want to build on that going forward.

In order to improve collaborative children’s services, we have undertaken a project exploring a collective leadership offer aligned to the delivery of GIRFEC. The GIRFEC Leadership Programme aims to increase capability and capacity around collective leadership in partnerships to drive forward integration and fully embed GIRFEC at the local level, using a ‘place-based’ approach, providing necessary support to leaders at all levels in their local partnerships, enabling them to apply learning to live situations as part of the ‘day job’. A trial of the Programme in two partnership areas (Argyll & Bute, and Fife), is currently on hold due to the impact of the coronavirus.

In addition, SG are working with local partnerships across Scotland to deliver a series regional leadership seminars to address common challenges, with a particular focus on collective leadership, integrated practice and GIRFEC. Four seminars have been delivered to date, with a further four currently on hold due to the ongoing coronavirus crisis.

Scottish Child Abuse Inquiry

In summer 2019, Phase 4 of hearings commenced with evidence relating to investigations into residential child care establishments run by male religious orders with a particular focus on:

  • Residential establishments run by the Congregation of Christian Brothers with a particular focus on their provision at St Ninian’s in Falkland, Fife.
  • The Order of Benedictines and their provision at Carlekemp in North Berwick and the Fort Augustus Abbey School.
  • In September 2019 a case study began into the Marist Brothers and their provision at St Joseph’s College, Dumfries and St Columba’s College in Largs.

The Inquiry has also published two case study findings to date on Daughters of Charity (October 2018) and Sisters of Nazareth (May 2019) with further case study findings to published in due course.

On 3 December 2019 Phase 4 of hearing began into the Child Migration case study. This phase relates to investigations into the abuse of children whose departure from Scotland to countries such as Canada, Australia and New Zealand was part of the child migration programmes.

A case study investigating abuse at residential boarding schools throughout Scotland is planned for later in 2020. Details of which schools will fall within the case study will be announced in due course. In 2019 Lady Smith announced that a case study will be held into foster care. This will include children who were boarded out as well as children who were placed in foster care. The Inquiry is recovering evidence from all 32 Scottish local authorities and is gathering evidence from applicants whose care was arranged by any Scottish authority. The case study is expected to begin in 2021.

On 12 May 2020 the Chair of the Inquiry, Lady Smith confirmed that the work of the Inquiry is continuing despite a pause in public hearings as part of the Covid-19 outbreak. Investigative work, research and analysis, and preparation for announced case studies continue.

Work on analysing  the evidence from the Christian Brothers, Benedictines and Marists case studies is well underway and findings will be published as soon as possible

Hearings relating to the child migration case study will resume in mid-September 2020. Subject to ongoing public health guidance and physical distancing measures,  it is hoped that the hearings will take place at the Inquiry’s hearing venue at Rosebery House and is likely to involve a combination of evidence from witnesses in person as well as remote evidence by video-link. Further details will be provided as soon as possible.

In August Lady Smith announced that in November 2020 the Inquiry will begin hearings which will examine the actions of central government in relation to issues arising out of non-recent abuse of children in institutional care


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