The CCTV User Group November 2007 National CCTV Strategy Analysis A Report by David M. White - CCTV User Group Executive Support Introduction After all the doubts, anticipation and conference presentations surrounding the proposed National CCTV Strategy it came as a sudden but welcomed surprise on the 19th October 2007 when Ian Cunningham contacted Peter Fry to announce its’ formal publication. We were ready with an instant press release based on collective thoughts and sight of the final draft document. Our instant reaction read: The CCTV User Group has welcomed the publication by the Home Office of the ‘’National CCTV Strategy’. CCTV has evolved hugely since the early nineties and now plays a fundamental role in crime reduction, public safety and an increasingly significant part in investigations. Having a coordinated approach, system compatibility and a clear direction to match the investment has been awaited since 1999 when the government encouraged growth through the Crime Reduction Programme CCTV Initiative. Whilst developments in technology have outpaced some of the capabilities within the police and justice system, the new National CCTV strategy aspires to meet the challenges so the benefits and full potential of CCTV can be maximised. The Group, which represents hundreds of public surveillance operators and managers across the UK, has been aware of much the detail now contained within the strategy since April and is encouraged by the work of the project team in addressing a national approach to issues like police use of CCTV, operating standards, inspection and enforcement, training, technological and managerial issues. Peter Fry, Director of the CCTV User Group commented: “This publication is long awaited good news. The number of public space CCTV systems in the UK – and the extent of their use – has increased considerably but on a localised basis. The 44 recommendations in the strategy represent considerable challenges for public systems that have invested and progressed but who will now seek to meet the requirements. We will be keen to assist the implementation team and offer appropriate guidance to all end-users in order to progress the strategy”. He added: “Initial reading provides a positive platform to develop the full potential of CCTV in the digital era and encourage all those in the police and justice system to fully embrace the changes. It reinforces our view of the need for common standards across many areas of CCTV management and operations but funding the implementation of the recommendations will concern many of our CCTV users”. Coupled with comments from the Strategy authors at our April conference in Manchester and minor extracts from the strategy’s executive summary, the above text formed an article in the November issue (No:23) of CCTVImage. Peter Fry wanted a more considered study. The analysis contained in this report is from my study of the Strategy supported by comments from colleagues in the Chairman’s Group; extracts from each source have woven their way into the body of the report. Given my past as a police officer and citycentre CCTV Manager; my experience gained since that time as a consultant and trainer within the world of CCTV operations, I have attempted to apply a holistic and objective mind to the analysis. Inevitably it will be my own reflection on behalf of the CCTV User Group and may not fully represent the views of the membership. From the outset I welcome the publication of the National CCTV Strategy. It may be a little too late for some who have made recent investments in new technology and overdue for many. It is better to have a direction rather than no direction at all. It represents centralised recognition from the top down of many pertinent issues and should provoke a more focused approach for those involved in the future of CCTV surveillance. National CCTV Strategy 1 29/07/2017 Overview The current HM Government have finally endorsed the success of CCTV in making streets safer, reducing the fears of becoming a victim and its value in investigating and detecting offences. On the back of massive government investment between 1994 and 2003 through Challenge Competitions and the Crime Reduction Programme, public space CCTV has grown extensively but in piecemeal fashion with little strategic direction. It is believed this approach has failed to maximise the potential of our CCTV infrastructure and many involved in its operation and management felt there remained a pressing need to examine existing standards, procedures, training and methods of operation. Changing threats have clearly focused minds on the benefits of CCTV and the need for its infrastructure to be improved by effective coordination and a clear future direction for users to follow. The National CCTV Strategy (hereafter referred to as ‘the Strategy’) published by the joint Home Office ACPO team led by DCC Graeme Gerrard and Ian Cunningham (HO), presents the results of a wide-ranging review of CCTV and its applications in the reduction of crime and in public safety. The report was commissioned in 2005 following concerns and risks identified by ACPO (CCTV). The Strategy is founded on a lot of work by a small team working with key stakeholders through extensive workshops and consultations. It reviews the use of CCTV to date, examining both its strengths and its weaknesses. The scope of the Strategy is ambitious and diverse; focusing largely on all public space CCTV but also seeks to embrace the private CCTV sector in the long term. It makes 44 recommendations for future action which represent a significant effort for all agencies involved in CCTV. Progress in these areas is extremely important if the full potential of CCTV across a varied range of uses is to be realised and continue to receive the support of the public. The Strategy is broadly based on the following 10 themes and examines each one in detail. The need for standards in all aspects of CCTV The need for clear guidelines on registration, inspection and enforcement Training of all personnel The police use of CCTV footage and evidence Storage / Volume / Archiving / Retention issues The need for CCTV Networks – Live & Stored Equipping, resourcing and standardisation within the CJS Emerging Technologies / Changing Threats / New & Changing Priorities Partnership Working Financial and Resource management This report will be structured to analyse the detail of each chapter from an end-user perspective and should be read in conjunction with the Strategy document. The threads running through the chapters and therefore the Strategy itself could be summed up as: Effective standards Concerns and risks relating to the transition to digital technologies Use of CCTV by police and the criminal justice system (CJS) Addressing the changing threats and crime profiles Stronger and a more dynamic partnership approach There are some recognised contradictions. Across many of the chapters you would be forgiven for thinking that the police and CJS were the only users of a CCTV system and its data, yet there is a desire for the town-centre CCTV control room to become a holistic hub for PSSCCTV. Retail, transport, leisure, local authorities and others all have different priorities for their cameras, making this a challenging aspiration. There is an important recognition within the strategy that there may be a conflict of interest between partners. Chapters 10 on Partnership working and 11 on Finances and Resources should have been at the head of the Strategy. The key issues raised are fundamentally crucial to progress of everything else. Government money may be scarce and more effective use of current funding is acknowledged but the outcomes here will determine long-term strategic success. National CCTV Strategy 2 29/07/2017 Chapter 1: Introduction This chapter offers a detailed insight into the background of public space surveillance, government funding streams, review background and its methodology. Much of this is familiar to many CCTV User Group members and is an accurate representation of the situation. It rightly acknowledges that Local Authorities continue to bear the burden for the ongoing costs of running and maintaining CCTV schemes whilst there are many other uses and users. Upon reading it does provoke thoughts of “where is the support funding?” This is so varied around the country and often it is none from any other third party. You are also left feeling that will the approach just be about policing and CJS requirements and outcomes? The strategy does go on to address these issues, albeit not in equal measure. It makes a valid point: It should also be remembered that while there exists a large number of local authority operated CCTV cameras, it is a very small proportion of the nation’s CCTV provision, since the vast majority are commercially owned. This surely endorses our view that the often quoted figure of 4.2 million cameras watching over the UK public is misleading. It identifies the opportunities and benefits of digital CCTV but recognises it brings a whole new set of difficulties for a future coordinated approach. Chapter 2: Standards With the deployment of CCTV commonplace in a variety of areas where the public have access, the strategy rightly identifies that the Data Protection Act 1998 offers the only statutory basis for systematic legal control of PSSCCTV. The enforceable information handling standards are crucial. Other than the DPA there are no statutory or legal obstacles to installing a CCTV camera or system. The DPA principles are highlighted. 2.2.1 Page 11: Incompatibility of new systems addresses the change from analogue to digital in the context of PAL and VHS were straightforward and common formats in most places. The increasing change to digital with the plethora of manufacturers, products and multiple proprietary formats creates procurement restrictions and image recovery and playback very difficult. There must be recognition here of the failure of both the police and the CJS to keep up. Even in the analogue era there is an example of where a CCTV system was using SVHS, the local courts were instructed to buy VHS recorders, which could not play SVHS tapes. This resulted in CCTV control room having to purchase and convert thousands of VHS tapes in addition to their SVHS tapes. Currently as systems move to digital recording, which can be played in any PC, some police forces have removed CD drives from the majority of their PC’s. The strategy later addresses theses issues in Chapter 5 but there needs to be a mention at this point. 2.2.2/3 Page 12: Picture quality and Operational requirements are highlighted and the release of the new HOSDB OR Manual 55/06 addresses many of the issues. Dr. Neil Cohen’s presentation to our Bristol conference 10/07 covers the actions around some of the Strategy recommendations. 2.2.4 Page13: Dual or multiple uses of CCTV cameras installed for one purpose being used for other purposes is reported as not effective in the context of pro-active crime orientated monitoring. Yet the dual use of traffic management cameras for crime surveillance when not in use for traffic is acceptable. There are conflicting expectations of investigating officers as to exactly what the remit for local use of CCTV is when they conduct post incident reviews and nothing has been recorded. There is clearly a need to include an element of education on these issues in the development of police training standards referred to elsewhere in the Strategy. National CCTV Strategy 3 29/07/2017 2.2.5 Page 14: Makes reference to the need to link crime mapping analytical tools and the National Intelligence Model (NIM) to determine the most effective deployment of CCTV cameras. This is helpful but will only be achieved in a trusting partnership where intelligence is shared and CCTV Managers are included actively in the (CDRP) Partnership; (final bullet point 10.2, page 44) 2.4 Recommendations: R2.1 Establish digital CCTV Standards – maybe a little late as many have made the leap but these standards are desperately needed to assist end-users in compatibility and procurement decisions. I believe ACPO are striving for a technical standards group now and the work that Dannie Parkes can offer the Chairman’s Group will be much valued as short-term advice for members before the national standards are/if devised. See also R 2.2 R 2.4 This drives a need for regular audit for CCTV owners and managers. We should be supporting this process and I believe it fits well with the revised ICO Codes of Practice for CCTV and the recommendation to carry this audit out upon the annual renewal of data processing notification. R 2.7 This guidance is well overdue and will be welcomed. R 2.9 This would be valuable work and surely we are in a good position to offer ourselves and past achievements here. It should be pointed out that large parts of this paragraph should apply equally to the 43 police forces in England and Wales and the co-located CJS. R 2.12 This is the recommendation that town-centre CCTV schemes should become the de-facto hub for all PSSCTV in their locality. This is a laudable suggestion but sadly quite often thwarted by the private sector organisations mentioned who prefer to run their own systems, mainly because their objectives are very different from public space systems. This one element alone would require a very dynamic partnership and much funding to achieve. It will be interesting how the Programme Board and the Implementation Team (IT) approach this future challenge. Chapter 3: Registration / Inspection / Enforcement This presents the detail behind the legal standards mentioned in Chapter 2. The revised ICO Codes for CCTV and our consultation response have been circulated to all members so this should address many issues here. The interesting aspect is the distinct registration of CCTV systems rather than them being subsumed in the general data processing notification to ICO. I welcome this approach and feel that the CCTV User Group can offer something to the IT with any database that we have. I can remember when the LGA compiled their green folder of all LGA CCTV schemes. Is that still done? Overall a useful chapter on direction for compliance standards. The main outcome here is the identified need to address the shortcomings around enforcement of the DPA and its’ Code. 3.4 Recommendations: R 3.1 Fully support this and believe the CCTV User Group should lobby proactively on this recommendation. R 3.2 The issues of inappropriate domestic CCTV exempt under S.36 DPA could be tackled here R 3.4 Fully supported. By addressing R 3.1 this can be achieved. R 3.6 Registration database should be supported together with general details of system audit to obtain an accurate picture of PSSCCTV in UK. User Group to assist here. National CCTV Strategy 4 29/07/2017 Chapter 4: Training I declare a vested interest here as this is a particular part of the future strategy that particularly interested me; the issue of Training. I am aware of the vast difference in training quality, qualifications and experience of trainers and the information provided in training facilities around the country. Training budgets spent on low quality training, that is often not fit for purpose is not meting the needs of the individual, their organisation or raising industry standards with consistency. The Strategy critically highlights: There is inadequate training for all staff engaged in CCTV. There are currently no uniform training standards that apply to all CCTV staff. It endorses a long-held view within the CCTV User Group that whilst the SIA Licence requirement has addressed minimum standards that should be achieved, it only applies to some and this is leading to disparity in the skill ranges and qualifications between staff. The SIA meet in early December 2007 to discuss the way forward for all PSSCCTV staff and we should be alert to the outcomes. The Strategy addresses the issue of little police training for CCTV and makes a clear point that there is a need for a uniform and comprehensive set of standards for training of all those involved in the use of CCTV; from operators to the police to the courts. This chapter is very clear and there is little to disagree with. The conclusions and recommendations are all good indicators for achievable future developments. 4.4 Recommendations: R 4.1 This clarification is long overdue and I hope the IT succeeds where others have failed with a conclusive answer from the SIA. R 4.2 A laudable recommendation and one that needs to be endorsed and promoted by the CCTV User Group. R 4.3 The outcome desired here is what we all want. It links to comment in the body of the main chapter: There are a variety of different bodies currently working on training and developing training standards. There is a need to bring these groups together and evaluate their findings and proposals. A concern is that whilst the ACPO CCTV Training Working Group, who are currently looking at developing a training programme in conjunction with Skills for Security, Skills for Justice, NPIA and stakeholders such as the police and CCTV Town Centre Managers, they (ACPO CCTV TWG) are working away in their own world and probably in many areas re-inventing the wheel over and over again. The Project Team really does need to ensure they work with the end users who have several years of experience in this field, do the job and know what is required. R 4.4 The CCTV User Group needs to offer fundamental support to the IT to achieve this. Chapter 5: Police Use of CCTV As the title suggests this chapter takes a detailed look at how the police and those in the CJS use CCTV across a range of areas. The introductory paragraph clearly identifies the use made and benefits of CCTV to the policing agencies in all aspects of their work. My initial comment in the margin was ‘but provide very little funding’. And that’s coming from a police force that was and remains proactive financially on CCTV issues. I know it’s a concern for many but it is addressed later in the Strategy (p 9 this report). How it improves is another matter. National CCTV Strategy 5 29/07/2017 The end-user will have little influence here, but the CCTV User Group should remain close to the Implementation Team (IT) to monitor the progress and any impact for our members. The interest will be how the police and CJS develop there ability to retrieve, manage and present digital CCTV data; formalising a standard job profile of the specialism (like DNA). Again the need for training is identified: There is an urgent need to develop an accredited training course for those engaged in the recovery and analysis of digitally recorded CCTV evidence. Closer to the end-user is 5.2.6 (p 27). It provides a welcomed approach to encouraging more consistent and open cooperation between police and LA CCTV, recognising productive relationships where CCTV is integrated into the policing function. The Strategy also highlights the fundamental need to provide operational feedback to CCTV; its’ absence often making it difficult to justify expenses associated with CCTV. 5.2.7 (p 28) addresses the wider application of CCTV by investigation agencies within the context of terrorism, beyond town-centres and volume crime. It concludes with an honest appreciation of the position within the police service and CJS: The development of the technology has outpaced the ability of the police service to respond to the operational opportunities. The lack of a national strategy or a co-ordinated approach to the development of CCTV has led to an ad hoc response that is less than adequate and fails to maximise the significant potential afforded by CCTV. This chapter serves notice by HO/ACPO to “police UK” to take a serious look at their approach to and performance standards around CCTV. 5.4 Recommendations: R 5.1 A little gem of contradiction here: Image retention periods should be standardised and should relate to the operational purpose of the CCTV system. Conflicts with DPA, ICO Codes and advice and the DPA principle 5 – ‘data not to be kept for longer than necessary’ (in the Strategy at 2.1 p 11). How can retention be standardised yet be flexible to individual operational purposes across a wide range of PSSCCTV? (see also 6.1 para 3, p31) R 5.8 We have published the outcome of this to members R 5.9 Agreed. CCTV User Group should work with the IT on this issue. Chapter 6: Storage / Volume /Archiving / Retention The introduction to this chapter speaks for itself and requires little comment. The only issue is the conflict (already highlighted above) at paragraph 3 about the police requirement for 31 day storage of digital data without quality being reduced or compromised (varied frame and compression rates) over that period. I believe this actually conflicts with ICO rather than the comfort expressed by ICO support. How will this be afforded if actioned? The key issues raised are well known to CCTV User Group members. Working to a standard is desirable but I believe it will be difficult to achieve in the short term. It would seem that all future CCTV Systems will have to be designed with ‘policing needs’ in mind to reduce conflicts over these topics at a later date. There are technical issues to be addressed by the IT for future solutions. 6.4 Recommendations: R 6.1 We await this guidance with interest R 6.2 Easily stated but we need to see how the IT develops this. National CCTV Strategy 6 29/07/2017 Chapter 7: CCTV Networks – Live & Stored This is happening now in limited circumstances but will no doubt feature increasingly over the next few years. Thames Valley Police CEDRIC IP interface from all CCTV control rooms over their area into the two Command centres is an example. The remote access to stored image data will grow and it is important to note the Strategy clear states networked access: is an indispensable requirement of modern day working. Appropriate access and permissions restrictions will need to be developed relating to the access of the images. The advantages are outlined in key issues at 7.2 p 35. The considerations surely have to be careful planning, more developments and pilot projects; most importantly, identify where the capital and revenue costs are going to come from. It terms of management the User Group wholly supports the key issue: Security, access and audit trails need to be stringent and continuing management scrutiny of the security, access and audit trails will be essential. This will be critical for any network solution. This has to be a longer term goal of the strategy. 7.4 Recommendations: R 7.1 CCTV User Group may be able to assist the IT with key member involvement. R 7.2 We could identify a member scheme willing to be a pilot project and be close to the developments. Chapter 8: Facilities in the CJS This chapter is a self-evident analysis of the current position and identifies needs for the future. It requires no further comment in my view. The strategic outcomes will be monitored with interest but little for end-users to do at this point. The playback standards and CPS guidance on evidence required will be helpful. Chapter 9: Change – Emerging technologies / Threats / Priorities The Strategy rightly identifies the need to face the future rather than just the ‘here and now’: without an element in the strategy that addressed how to deal in the future with change, there would always be an element of playing ‘catch up’. It is ambitious in that it addresses technical issues for the next 10 years but that could be an impossible task given the rapid rate of change. There are some useful and interesting key issues. Convergence and integrated systems (which will lead to an increase in ‘multifunctional control rooms’) are highlighted as able to: dramatically improve the effectiveness of CCTV systems and (or but…) significantly increase the capacity to undertake public surveillance and therefore needs to be carefully controlled by Information and Surveillance Commissioners’ guidance; a careful balance between technical progress and compliance requirements. Beyond the technology is the change in threat and the CCTV response to it. To meet these national strategic aims, issues for CCTV User Group members to consider in their future plans will be at 9.2.2 (p 41) Camera locations based on NIM and NTA principles; Specialist training and vetting levels for staff Appropriate intelligence sharing National CCTV Strategy 7 29/07/2017 At 9.2.3 the changes are broadened into more general crime issues and the need to be flexible in responses to changes in local, current crime trends as well as environmental changes. It recommends more should be done to ensure cameras can be redeployed to ‘hot-spots’. This will surely impact on the ever increasing use of Redeployable camera units and all the operational issues. Significantly the need for more two-way flow of intelligence to support the delivery of flexibility is highlighted. For many this is long overdue and needs to be implemented in a national, consistent manner with some urgency if the full potential of existing CCTV (never mind the future) is to be maximised. It is fair to point out, many CCTV systems have already converted or have started to convert to digital recording systems and some are now toying with IT and Broadband broadcast system in preference to traditional cables. In addition a number of systems have started to use wireless and infrared cameras to give them greater flexibility and to reduce costs. In that context this document is too little too late for some. The recommendation (R 9.3) that digital CCTV standards be developed with government agencies and manufacturers should have taken place five years ago before people started to convert from analogue. So what is a standardised system and how do you get people onto it? By the time we get a standardised digital system, new technology will have arrived. Realistically the chances of standardising the re-deployable camera transmission systems and digital recording systems will take five to ten years to achieve because systems which have just spent £100,000+ on a system are not going to throw it out just because the implementation of this recommendation states otherwise. Likewise now is the time that strategies on alternative forms of camera transmission (wireless, IP, Broadband, Mesh etc) should be discussed because all CCTV systems are looking for alternatives to cabling. 9.4 Recommendations: R 9.3 See comments above R 9.5 See comments above Chapter 10: Partnership Working This is an issue close to the hearts of many CCTV User Group members. This chapter makes some excellent points and I reiterate my introductory comments that this chapter (and the following one) should head the implementation of the strategy in order for successful outcomes to be achieved. Effective partnerships are described as those: Where small groups work more closely together in a locality That build strong relationships police Engage the private sector CCTV schemes for an integrated service At bullet-point 3 at the bottom of page 43 it rightly acknowledges that whilst a joined-up approach has benefits it may also lead to a conflict of interests between certain stakeholders. A local authority may have agendas that differ from that of the police or CJS. If linked to private CCTV schemes, all have different priorities for their cameras. Not only that but different systems within each group may also not agree on their objectives. This is fuelled by local attitudes and considerations and commercial requirements. So how does this sit with the strategic aim of town-centre CCTV control room becoming the holistic hub? We will wait with interest in how the IT develop this one. National CCTV Strategy 8 29/07/2017 Effective partnerships are ones that work together and deliver results. To address this point and potential conflict of interests, this chapter highlights the issues (p 44): Determine primacy and priority issues Identify ‘access to recorded material’ protocols Common technical standards to achieve compatibility Include the CCTV Manager as a member of the local CDRP Whilst the final chapter deals with Financial Resources, there is a significant bullet-point here that goes to the heart of the difficulty in many partnerships: The issue of funding and bearing the running costs for the system has also been seen to cause some concern for CCTV Town Centre managers. The systems are set up and controlled by local authorities; however CCTV benefits a wide range of groups, including the police and the wider CJS. CCTV impacts significantly on community safety which is a statutory obligation for a number of agencies. There is therefore a desire for contribution towards the running costs from areas other than local government funding. I refer to my comment at page 5 about police contributions: ‘but [they] provide very little funding’. This is some comfort that the issue is acknowledged but I stand by my point; how it improves is another matter. (See R 11.2 p49 of Strategy document) 10.4 Recommendations: R 10.1 Unsure whether this reference to a ‘National Board’ is the same as the National Strategy Programme Board in the Partnership Model at the end of Chapter 10. R 10.2 Agreed. Recent ACPO Airwave advice covers much of this. R 10.3 Good model. Be interesting to see it applied to multiple LA CCTV schemes. R 10.5 Primacy at local level taking into account the Strategy. The strategy contradicts itself here and needs to provide clear unambiguous guidance if it is to be achieved. Partnership Model Partnerships Steering Stream: the CCTV User Group should be active here with PCMA for CCTV Managers and LGA Registration & Inspection Stream: the Office of Surveillance Commissioners (OSC) is missing here. Comment: How does this embrace the private sector in the long term? Chapter 11: Management / Financial / Resources Whilst management of the strategic delivery nationally (NSPB) and locally (CDRP’s) has particular importance, the funding and sustainability of CCTV is critical to everything else. One of the most important issues the Strategy identifies comes in this last chapter: Who or what will fund the provision of CCTV? This is a key issue that is currently preventing CCTV being used more widely and effectively and in limiting cooperation with other partners. The remaining key issues covered relate to topics already in the PSSCCTV arena nad have been subject of presentations at our conferences; combined / national procurement, KPI’s and lack of feedback from police and CPS. National CCTV Strategy 9 29/07/2017 The CCTV User Group can certainly agree with the conclusions here: Funding issue is a serious threat to the future of CCTV, whether it affects the installation of cameras in areas that currently do not benefit from CCTV, or its expansion and growth into the type of network that has been suggested by the previous chapters, or how it is used by the police or within the CJS. The effectiveness of CCTV schemes cannot be properly assessed by the direct relation to crime statistics alone. There are so many intangible benefits in the policing and justice systems as well as community safety with reassuring perceived fears. There is no single body that has responsibility and is accountable for CCTV in this country – or for setting performance standards, reviews, improvements or determining best value and cost effective solutions. 11.4 Recommendations: R 11.2 Fully agree with the 4 points listed… but: Government says no new funding; make better use of what is currently available; How will the police respond? The contradictions have already been highlighted about the income generation opportunities –v- conflicts of interest. Clarity and consistency in the Strategy is necessary. The authors do add the caveat: This last point is an increasing worry from a police perspective R 11.3 Agreed. Would enable a national assessment rather than what we can seek to achieve amongst our own membership. R 11.4 Is there an opportunity for our own UK Standards Board / Chairman’s Group to assist with devising a model for this issue? Chapter 12: Summary of Recommendations Indexed 1 – 44 for ease of reference across the individual Chapter references. Chapter 13: The Next Stage National Strategy Programme Board (as per Partnership Model at the end of Chapter 10) Form the multi-agency Implementation Team 12 month implementation phase which will prioritise and develop the recommendations. The CCTV User Group management team should consider the role of our organisation in the assistance to the IT; who and how that is to be delivered. We all accept it has some short term achievables (some in part or fully completed) but much is a long term vision. With the funding addressed and more effective partnerships developed, then the platform is set for progress. Let’s not miss the opportunity to strive for success and the User Group is well placed to participate on behalf of its’ membership. National CCTV Strategy 10 29/07/2017
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