From 1 July 2024, a broader range of workers will be covered under the Reportable Conduct Scheme (Scheme) in Victoria, including workers indirectly engaged by an organisation, such as labour hire workers, secondees, directors of companies, individual business owners and students undertaking placements. Previously, the head of entity of an organisation covered by the Scheme was only required to report and investigate allegations of child abuse (known as ‘reportable allegations’ under the Child Wellbeing and Safety Act 2005 (Vic)) by workers with a more formal or direct relationship with the organisation, including employees, contractors and volunteers (including volunteer board members).
In light of these new changes, organisations should carefully consider whether they need to report and investigate reportable allegations against a broader range of workers, and whether their child safety policy, procedure and code of conduct should be updated and communicated to workers.
Currently, organisations are required to make reports to the Commission for Children and Young People (CCYP) and investigate reportable allegations in relation to workers, including employees, contractors and volunteers. The new changes expand the workers covered under the Scheme and will now include:
A labour hire worker and secondee will be covered under the Scheme when:
A number of factors will be considered including:
This requires assessment of each worker based on the individual circumstances of their engagement. For example, the following workers will now likely be covered by the Scheme:
In these cases, the head of the organisation in which the worker is placed will now have an obligation to report and investigate reportable allegations against the worker.
Where an organisation engages a company to perform work and the director of the company performs the work, the director will be considered a worker of the organisation for the purposes of the Scheme. It is irrelevant whether the company engaged is covered by the Scheme.
For example, where an IT company is engaged by a school to upgrade their computer system and the director of the IT company is the person who completes the upgrades, the head of entity at the school will likely be required to make a report if they receive a reportable allegation about the director.
An individual business owner (also known as a sole trader) will now be covered under the Scheme where:
This amendment clarifies that individual business owners will be subject to the Scheme in the same way as the workers they engage.
For example, where a business owner of an overnight camp for children engages staff to run the camp, the business owner will now be covered under the Scheme.
Students undertaking placements, such as a student teacher undertaking a placement at a school, may be covered by the expanded definition depending on the arrangements of their placement. The key considerations are:
The expanded definition also has implications for the obligations of an organisation to report historical allegations. If an entity receives a historical allegation about a worker covered under the expanded definition after 1 July 2024, the entity may be required to make a report to the CCYP. Whether a report needs to be made will depend on:
For example, if a principal of a school becomes aware of a reportable allegation against a casual relief teacher who is engaged via a labour hire agreement on 3 July 2024 (i.e. after 1 July 2024) which is alleged to have occurred while the casual relief teacher was working at the school in 2012, the principal may be required to report the allegation to CCYP and investigate the allegation.
For further information about reporting historical allegations, please see the CCYP Information sheet which provides diagrams showing how the considerations will impact the requirement to report.
We recommend that organisations review their policies, procedures, code of conduct, contracts and agreements to ensure that they accurately reflect the expanded coverage of the Scheme, and communicate those changes to relevant workers.
Moores can assist to:
If your organisation needs assistance in determining how these changes impact you, please contact our Safeguarding Team.
Please contact us for more detailed and tailored help.
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Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.
Suppose a parent calls your office and requests their child’s counselling records? Or a court order lands on your desk seeking access to counselling notes? Or perhaps, your school counsellor raises concerns about a student’s wellbeing and wants to discuss information shared in a counselling session? When can you disclose a student’s counselling records and when should you not? This is a question that is becoming increasingly problematic for schools. The answer lies in balancing the duty of care with confidentiality and privacy requirements. This article will set out your legal obligations and answer some common questions in this space.
Schools owe a duty of care to their students and all children under common law and state-based legislation. The duty is generally to take reasonable care to protect students from harm which is reasonably foreseeable. Several states including New South Wales, Victoria, South Australia and Queensland have reversed this onus in relation to child abuse caused by an individual associated with the organisation.
To help facilitate student wellbeing, most schools have a counsellor, psychologist or pastoral care available to students. In these sessions, personal information will be collected by the school including medical information, relationship status, familial issues, disclosure of bullying or mental health concerns and other sensitive information.
Schools are required to handle this information in accordance Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles (APPs) and state-based legislation. For example, the information collected can only be used for the primary purpose (in this case being the provision of counselling services) unless a permissible secondary purpose exists. Permissible secondary purposes include those related to the primary purpose, where consent is provided, the disclosure is authorised under Australian law or a court order or a permitted health situation exists. The Australian Psychological Society takes the position that a psychologist is obliged to release information when “required by law”, which includes the law which imposes a duty of care on schools.
Do I need the student’s consent to disclose their counselling records to their parents?
It will depend on the age of the student. The Office of the Australian Information Commissioner (OAIC) recognises that a child’s capacity to consent to the handling of personal information needs to be determined on a case by case basis depending on the maturity and ability to sufficiently understand what is being proposed. As a general rule, schools can presume that students aged 15 and over have capacity to consent. While the Privacy Act doesn’t currently specify a specific age, predicted amendments may define a child as 15 or 18. For Victorian schools, the Victorian Privacy and Data Protection Act 2014 (Vic) defines a child as someone under 18 years of age, but does not specify the age when individuals can make their own privacy decisions.
Many secondary schools state in their policies or counselling intake or permission forms that all students from year 7 will be required to give consent for the release of their counselling records (unless an exception applies). We recommend that schools decide what their policy will be and embed this into their documents to ensure there is clarity amongst students and parents.
What if one parent is requesting the information but the other parent or student does not agree?
Schools can be caught in a tricky situation where parents disagree on the disclosure of counselling records, especially if the parents are separated or in the process of separating. First and foremost, if the student is able to consent, the school should seek the student’s consent. This rings true with other child safety obligations for the empowerment of children. If the student does not, or is unable to, consent, schools should seek consent from both parents before disclosing any records. This is particularly where the records contain sensitive information. If the parents cannot agree on the disclosure, the school should request a court order before disclosing any records.
What about requests from third parties?
Schools should be careful about releasing counselling records or information to third parties without the proper consent from the student or their parents. Schools should always require any such request to be in writing. If the student or their parents do not consent, it may be that the school requires further advice on whether or not they are required to provide the records. Most states (Victoria, NSW, Queensland, South Australia) have introduced information sharing schemes, as recommended by the Royal Commission into Institutional Responses to Child Sexual Abuse, which permit the sharing of confidential information to organisations in limited circumstances for the purpose of safeguarding children. We explain the Victorian Child Information Sharing Scheme here. In the absence of an applicable information sharing scheme or court order permitting a disclosure to a third party, refer to APP 6.
What about requests from former students about their own records?
We have received queries from schools concerned about providing former students with their own counselling records, especially where the former student may be considering a historical child abuse claim or other claim against the school. APP 12 requires organisations give individuals access to their own information on request. While there are some exceptions to this, they are limited. One such exception is if the record includes personal information belonging to other individuals and the sharing of that information would have an unreasonable impact of those other individuals. If an exception applies, the school may have grounds to refuse or redact information. More information about handling information access requests is here.
The counsellor, psychologist, wellbeing officer or chaplain is concerned about a student – what should we do with this information?
Where a staff member is concerned about a student’s wellbeing, that staff member can share that information within the school with other limited and appropriate staff for the purpose of the student’s safety or the discharge of the duty of care. Always share information in accordance with your policies and procedures. While the privacy obligations under the Privacy Act apply to the school not the individual, internal sharing of the information should be on a need to know basis. At the same time, the school needs to ensure that it is fulfilling its duty of care. Where concern for a student’s wellbeing rises to the level of needing to make a report to an external organisation such as Child Protection, this should be done and is an exception to obligations under the Privacy Act (see below).
When do I have to provide counselling records?
There will be situations when the school is required to disclose the information held in counselling records. This includes:
The above situations (amongst others) are exceptions under the Privacy Act and the disclosure of information without consent is permitted.
Managing requests and disclosures of counselling records is a difficult topic and often requires decisions to be made in short timeframes. Where records are incorrectly disclosed, schools could find themselves at risk of various claims including breach of privacy (with increased significant maximum penalties) or negligence. To mitigate these risks, we recommend that schools:
At Moores we have a specialised team that supports the education sector on a variety of areas including privacy and data security. This makes us well placed to assist schools in the careful balance of duty of care with confidentiality and privacy requirements.
We are more than happy to guide you through the process of determining your obligations in disclosing a student’s counselling or pastoral care records.
This article was originally published November 2019. Updated June 2024.
In September 2023 TikTok was fined 345 million euros (the equivalent of $575 million AUD) by the Irish Data Protection Commission (DPC) under the European General Data Protection Regulation (GDPR) for breaches in its processes of children’s personal data. The basis for the fine is a lack of transparency through vague language explaining TikTok’s data handling processes and a failure to implement privacy-by-design in automatically making children’s accounts public. Another important part of the decision is consideration of age-verification measures.
We have written previously about children’s privacy, as it is an intersection of privacy and child safety similar to our annual eSafety campaigns for Safer Internet Day each February. More information on these topics is here:
This article considers three key aspects of the TikTok fine – transparency, privacy-by-design, and age-verification measures – in the context of Australian privacy regulation as it is relevant for charities and schools who work with children.
Transparency is a pillar of privacy regulation, in both Europe and Australia. In the TikTok decision, the DPC took issue with certain vague words: the use of “public,” “everyone” and “anyone” to describe who could see a user’s account was not sufficiently clear as to whether that meant all registered TikTok users or anyone who could access the platform. Another transparency breach was the failure to provide information about TikTok’s information handling processes in a concise, transparent, intelligible and easily accessible form, using clear and plain language. We encourage all organisations to ensure their privacy policies and collection notices are clear, easy to understand and tailored to their particular audience.
In Australia, Australian Privacy Principle 1 enshrines openness and transparency as requirements for how organisations handle personal information. Specifically, openness and transparency means:
Further, improving transparency of organisations and control of individuals is a key aim of proposed amendments to the Privacy Act 1988 (Cth).1 The reforms propose to increase transparency and control with improved notice and consent mechanisms. This is, in part, in response to the 2023 Office of the Australian Information Commissioner (OAIC) Australian Community Attitudes to Privacy Survey which showed that 84% of Australians want more control over the collection and use of their personal information.
For charities and schools, ensuring you provide transparency and control is critical to maintaining a strong and healthy relationship of trust with your community members. Transparency is a pillar of privacy regulation because privacy recognises that handling over information about ourselves or our children can be personal; similar to handling over part of our identity. Privacy, and transparency, is inherently about trust.
We previously discussed what we mean by privacy-by-design in a recent article. For TikTok, it was found that making children’s accounts public by default is inconsistent with the GDPR’s data protection by design and default obligations. This was partly because TikTok, through its web browser version, can be access by non-registered users; i.e., the public at large. An additional, specific setting was required to “Go private”.
In Australia, no obligation regarding privacy-be-design currently exists. The inclusion of a privacy-by-design requirement is possible in the proposed amendments. What the government has committed to is to implement “new organisational accountability requirements [that] will encourage entities to incorporate privacy-by-design into their operating processes.” Regardless of a compliance obligation, privacy-by-design is a strong risk mitigation step against the threat of data breaches because:
Privacy-by-design is particularly relevant to children’s privacy, as the Government agrees with the recommendation from the Attorney-General’s Department to introduce a Children’s Online Privacy code.2 The code would apply to online services that are likely to be accessed by children.
However, the decision is novel from a pan-European/EDPB (European Data Protection Board) perspective insofar as it is the first to examine age-verification measures against the backdrop of the GDPR. While the EDPB’s dispute resolution procedure, in an arguably rather odd way, directed the DPC to reach an inconclusive outcome, there are some important markers digital services with a mixed user population should note, as they may be indicators of future regulatory approaches to age verification.
The decision reaffirms the major focus of European regulators — and moreover the DPC as the bloc leader in this area — on children’s data. This is a topic we expect to see increasingly more often in regulatory investigations and enforcement decisions.
The DPC’s findings regarding the risks to children from the processing of their data are informative of how the DPC will expect organisations to assess such risks in relation to their own processing operations.
Finally, the decision also signals the EDPB’s willingness to use the fairness principle to bolt on additional findings of infringement at the dispute resolution stage, even where the lead supervisory authority’s investigation did include such an issue within its scope.
Read our latest article more detail on how the DCP came to their decision against TikTok.
With the growing focus from both Europe and Australia on children’s data, organisations that work with children must take careful consideration of how they handle personal information.
Our privacy and data security team work with organisations to create workable and compliant privacy frameworks, and implement information handling practices that are resilient to data security threats. Our deep understanding of the education and not-for-profit sectors means that we are well equipped to support organisation that work with children on privacy requirements.
1Australian Government, Government Response to the Privacy Act Review Report (28 September 2023).
2Australian Government, Government Response to the Privacy Act Review Report (28 September 2023), page 13; Attorney-General’s Department, Privacy Act Review: Final Report (23 February 2023) Proposal 16.5.
The Minimum Practice Standards: Specialist and Community Support Services Responding to Child Sexual Abuse (Standards) were launched on Wednesday 6 September 2023 under the National Strategy to Prevent and Respond to Child Sexual Abuse 2021-2030.
The Standards embed the three core values of being victim and survivor centered, trauma-informed, and culturally safe, across the six standards.
The Standards apply to specialist and community support services responding to child sexual abuse, including:
The Standards are not intended to apply to:
However, all organisations and services will benefit from drawing from the Standards to improve their responses to child sexual abuse.
Helpfully, under each standard are ‘standard indicators’ which organisations can draw from to implement each standard within their own practices and services.
Our Safeguarding team can assist your organisation to draw on the Standards to strengthen your organisation’s practices when responding to and preventing child sexual abuse. Our team of experts can support your entire organisation to comply with the Standards, from providing guidance to your Board, through to policy development and delivering staff training. Contact Skye Rose or Cecelia Irvine-So for more information about how we can support your organisation to take this incredibly important step to providing a safe environment for all children.
We know that discrimination negatively impacts on the ability of students with a disability to participate and maximise their potential in the school environment.
In our experience, schools work hard to provide a broad range of reasonable adjustments to support students with disabilities. Schools are generally familiar with the requirements under state and federal anti-discrimination laws that students with a disability have access to education on the same basis as their peers.
What schools may be less familiar with is the vulnerability of students with a disability to child abuse or risk of harm. This vulnerability is well documented. The Royal Commission into Institutional Responses to Child Sexual Abuse heard evidence that children with a disability can face additional barriers to disclosure of child abuse or harm. Students with a disability are also more likely to be subjected to restraint or seclusion and are more likely to be bullied. The importance of protecting the safety, welfare and best interests of children with a disability is reflected in the National Principles for Child Safe Organisations, which includes a key principle that equity is upheld, and diverse needs respected in policy and practice. Ministerial Order 1359, which implements the Child Safe Standards for Schools in Victoria, reinforces this principle by legally requiring schools to pay particular attention to the needs of students with disabilities.
So what does this all mean and what actions can schools take to ensure child safety for students with a disability?
Below are just a few tips for schools to ensure child safety for students with a disability and comply with their legal obligations:
Our Child Safety team can help you to develop a best practice Child Safety Policy and Procedure and Child Safety Code of Conduct. We can also run some of the leading child safety training in Australia for both staff and for older students. If a child safety issue arises, we can support you in your response and investigation. Contact to us to hear more about these services.
The September school holidays are around the corner, and summer holidays will be here before we know it. With holidays can come students going to parties, drinking, taking “compromising” photos and spending many more hours than usual on social media. As part of our work for National Child Protection Week (3 to 9 September 2023), we’ve reflected on the key risks to young people heading into school holidays and the extent of the school’s duty of care in that holiday period.
It is the duty of schools and teachers to take reasonable steps to reduce the risk of reasonably foreseeable harm occurring.
The extent of the duty of care has steadily been increasing in recent years, both through legislative tools (Ministerial Order 1359) and case law. We’ve previously explained the expanding “school environment” and decision of PCB v Geelong College [2021] VSC 633. The key takeaway from this case was that schools can be responsible for the acts of third parties, who are volunteers, or members of community groups, when the school facilitates the introduction or connection with students, and risks are reasonably foreseeable but not addressed.
Discharging the duty of care means understanding what reasonably foreseeable risks students are facing. Over school holidays, we have seen risks of:
Schools cannot, and are not expected, to prevent any harm occurring. Instead, the duty is to take reasonable steps to mitigate the risk of these harms occurring. Schools may well have a duty of care to students even on term break, particularly where behaviour involves another student from the school. Once the school is informed of any issues, it needs to act and take reasonable steps to investigate. Whilst general reminders are insufficient to discharge the duty of care with respect to known incidents, a reasonable step towards discharging the duty of care will often be education. With the reduced level of supervision and oversight over school holidays, providing students with information about their rights, responsibilities and how to seek help and support can prevent harm occurring, and/or escalating. It is a requirement under the Ministerial Order 1359 that schools:
Schools should use end of term assemblies and communications to reiterate:
We offer training for school staff about the duty of care, online safety and how to respond to identified risks of harm to students. We also offer information sessions and seminars for students to informed students about their rights and responsibilities, both in terms of the affirmative consent model and being a digital citizen to students as part of our Safeguarding and Child Safety work.
Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to your organisation.
1eSafety, Digital Lives of Aussie teens (2021) page 5. You can download the full report here: https://www.esafety.gov.au/research/digital-lives-aussie-teens
2 eSafety, Digital Lives of Aussie teens (2021) page 11. You can download the full report here: https://www.esafety.gov.au/research/digital-lives-aussie-teens
Conducting investigations in relation to employee conduct always requires careful consideration and compliance with requirements of procedural fairness. However, when the conduct being investigated involves children, this raises several additional complexities which must be considered by employers.
The case of Gulliver v Corporation of the Trustees of the Roman Catholic Archdiocese of Brisbane [2023] FCA 823 (Gulliver) highlights the need for a sensitive approach to these types of allegations, balanced with compliance with any processes set out in an enterprise agreement. This case resulted in an employer being required to pay over $50,000 in penalties as a result of failure to comply with a direction from the Fair Work Commission (FWC), in accordance with its obligations under the applicable enterprise agreement. While this case drives home the need for employers to properly consider requests for further information in accordance with relevant industrial instruments, it also highlights the complex child safety and privacy obligations that must be carefully considered, which vary between jurisdictions.
The applicant was a teacher employed at a school managed by the respondent, who traded as Brisbane Catholic Education, for over 15 years. The employment relationship between the teacher and Brisbane Catholic Education was governed by the Catholic Employing Authorities Single Enterprise Collective Agreement — Diocesan Schools of Queensland 2019–2023 Agreement (Enterprise Agreement). The Enterprise Agreement was a workplace instrument and an Enterprise Agreement for the purposes of the Fair Work Act 2009 (Cth) (FWA).
By letter dated 7 February 2023, the teacher was advised by Brisbane Catholic Education that an investigation had been commenced in relation to the teacher’s conduct in the course of her employment. The alleged conduct involved the teacher tugging the earlobes of two students when demonstrating the appropriate sleeper earrings to be worn in accordance with the school’s policy. In further correspondence from Brisbane Catholic Education, the teacher was informed that the allegations had been substantiated.
The teacher subsequently sought details of the evidence being relied upon in the investigation, however, was only provided with select, paraphrased information in relation to the allegations being investigated. The teacher then applied to the FWC seeking a range of remedies, including an injunction preventing Brisbane Catholic Education from terminating her employment until completion of the dispute resolution procedures set out in the Enterprise Agreement. Notably, the Enterprise Agreement contained status quo provisions which stated:
2.4.8 Whilst all of the above procedure is being followed, normal work shall continue except in the case of a genuine safety issue.
2.4.9 The status quo existing before the emergence of the grievance or dispute is to continue whilst the above procedure is being followed.
The FWC, in its reasons found that the Enterprise Agreement’s guidelines surrounding complaints against employees did not “compel” Brisbane Catholic Education to provide the teacher with the material sought. However, the FWC recommended in the particular circumstances of this case, that “the sensible course is for [Brisbane Catholic Education] to provide to the [teacher] to the full extent that is permissible, any material that will be put before the decision maker before a final decision is made”.
Brisbane Catholic Education failed to provide any further details in relation to the conduct, and subsequently terminated the teacher on the basis of the alleged conduct on 31 May 2023.
The teacher therefore claimed that Brisbane Catholic Education contravened s 50 of the FWA by contravening the status quo maintenance provisions contained in her Enterprise Agreement.
The Court held that there was a contravention of s 50 of the FWA on the basis of the contravention of the Enterprise Agreement requiring the status quo to be upheld during the dispute resolution process set out in the Enterprise Agreement.
The Court found that the teacher was “left in a position of not knowing, prior to her dismissal, whether or not [Brisbane Catholic Education] would act on the recommendation” made by the FWC.
“Had [Brisbane Catholic Education] chosen to act on the recommendation by communication to her, even if only to the extent of stating, “You already have, by correspondence of particular dates, the following material and this is the only material which will be placed before the decision-maker”, she would then have had the choice of whether or not to accept that this was in fulfilment of the recommendation or, had she chosen to want more, to press for an arbitrated outcome.”
Instead, the Court found that by failing to do so, Brisbane Catholic Education, by the termination the teacher’s employment without providing any indication of its position in relation to the recommendation, was to interrupt the status quo.
Consequently, the Court was satisfied that the contravention had been made out, being a violation of a status quo required by clause 2.4.9 of the Enterprise Agreement.
As a result of this contravention and having found liability, the Court awarded $28,832.76 compensation for economic loss and a further $25,000 penalty for the breach of s 50 of the FWA.
We advise clients on employment and safeguarding investigations across Australia and can provide assistance on the best way to navigate these complex issues, consistent with relevant laws and industrial instruments. With our expertise in both workplace relations and child safety, Moores are well-placed to assist with managing misconduct investigations that overlap with reportable conduct in relation to children. Please contact Skye Rose for further advice or information.
The Online Safety Act 2021 (Cth), which passed parliament in 2021, officially came into effect on 23 January 2022. Reforms include a world first scheme to take down cyber abuse and better protect children and adults from online bullying.
The eSafety Commissioner, Julie Inman Grant, has also been given authority to order online platforms to remove the worst of the worst content. This includes child sexual abuse material, irrespective of where it is hosted. In addition, the laws modify a scheme already in place for reporting the online bullying of children, broadening who they apply to beyond social media platforms, and shortening the removal timeframe to 24 hours from 48 hours.
The Cyberbullying Scheme allows individuals to make a complaint about cyberbullying material that targets a child (under 18). A report must be made to the relevant online service provider before a complaint is made.
Cyberbullying material means online communication to or about a child that is seriously threatening, seriously intimidating, seriously harassing or seriously humiliating. It can include posts, comments, emails, messages, memes, images and videos.
eSafety can issue a notice to the online service provider requiring removal of the cyberbullying material. Where providers fail to comply with notices, eSafety can take enforcement action such as injunctive action or seek civil penalties (fines).
For child safe organisations, the Cyberbullying Scheme means you can refer individuals (child or their parents, as appropriate) to the eSafety Commissioner to make a complaint if cyberbullying occurs.
The changes to the Image-Based Abuse Scheme give eSafety the power to issue notices for the removal of intimate images or videos shared online, without the consent of the person shown.
There is a general prohibition on image-based abuse – sharing or threatening to share intimate images or videos online without consent – which means any person may make a complaint about breaches of this prohibition. For child safe organisations, this means you could yourselves make a complaint, should image-based abuse come to light in your organisation. In these circumstances, we would also encourage organisations to consider the rights of the child to be involved in decisions that affect them, and refer organisations to the Child Safe Standards.
The Basic Online Safety Expectations put into law what the Australian Government now expects from online service providers. eSafety is, of course, the main priority of the Basic Online Safety Expectations, however, the tech industry is also encouraged to be more transparent about their safety features, policies and practices.
Expectations of online service providers include:
For child safe organisations, this means:
Still want to know more about online safety and the eSafety Commissioner? Look out for information on these topics from Moores in February.
If you would like any more information about what the changes to the Online Safety Act 2021 mean for your organisation or steps you can take to protect children from online harm, please do not hesitate to contact us.
The unprecedented nature of 2020 had a significant impact on child safety. Most organisations were required to shift the majority, if not all, of their interactions with children online. At the same time, many anticipated legislative reforms were postponed for a year.
As your organisation begins to plan for 2021, child safety needs to remain a key priority. Organisations need to be aware of the latest trends, developments and legislative reforms. We recommend that organisations take proactive steps to strengthen their approach to child safety.
Download our free guide by registering below to help your organisation set out your child safety agenda for 2021.
For more information regarding your child safety obligations, please do not hesitate to contact us.
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