The Accurate Perception of Truth

Many will be aware that a legal petition brought on behalf of an attendee of Teviot Day Service was the subject of a Judicial Review at the Court of Session in Edinburgh on 28 April this year. The case, brought against Scottish Borders Council, asserted that SBC closed down Teviot Day Service without proper consultation or adherence to their statutory legal obligations. This is basically what Teviot Day Service Support Group has been saying to SBC for 3 years. SBC has consistently denied these claims, right from the officials & senior officials involved, up to & including 2 consecutive Chief Executives, both now departed from their posts. 

TDSSG's campaign has been consistently supported by local Councillors Watson McAteer, Stuart Marshall & Clair Ramage. In addition, there have been many volunteers in the Group who have attended meetings, given up their time to help, gathered signatures for our petition & continued to support the campaign to keep Teviot Day Service open. We have had the support of Borders Carers Centre & Borders Care Voice too. 

Of course the start of the Covid pandemic gave SBC the perfect reason to close TDS. Whilst we understood this had to be done on a temporary basis, SBC used it as the basis for permanent closure, the ultimate ploy being to relocate the RVS Social Centre into the space in the Katharine Elliot Centre which was previously used by TDS, thereby preventing the possibility of TDS being reopened. In the interim period also, SBC had redeployed TDS staff, in some cases effectively causing them to leave (& with them, the loss of so many years' professional expertise) & in addition were able to proclaim 'no new referrals can be made to a service which is currently closed & in the process of being decommissioned', preventing access to those whose only suitable support & engagement service was a buildings based Day Service & removing what little respite options family carers previously had available to them. SBC officials tried to tell us (& others) that the RVS Social Centre could provide an equivalent service - we proved this to be nonsense for those with higher levels of needs & predictably, the RVS Social Centre said they couldn't cope. They should never have been put in this position in the first place because the RVS Social Centre cannot (& RVS has been very clear about this) provide an equivalent service to Teviot Day Service for those who need professional Day Service care. 

We tried everything we could to reason with SBC over 3 years - meetings, evidence, letters, emails, involvement of local Councillors, MP & MSP, petition. All we received was the pretence of listening to us & working with us to address our concerns. There was never any intention to consider the option that buildings based day services for older adults continues to be needed nor any willingness whatsoever to consider that perhaps SBC's strategy was not quite right.

When we uncovered evidence of what we believed was false & deliberately misleading statements, we took it to the then (& apparently now short lived) Chief Executive, Netta Meadows, only to be told 'my perception of the truth is different from your perception of the truth'.

That was when we decided to launch our petition with which we achieved a modicum of success in November 2021, thanks to the Audit & Scrutiny Committee (though there were some Councillors on that too who appeared to exist on a different plane of reality). However, that Committee has no powers with regard to judging or changing decisions already made so as a last resort we sought legal advice. This was not a route entered into lightly & we did so with full awareness that it would likely cost a great deal of public money. However, the pursuit of this case was not simply about one person or even TDS - this case was needed to demonstrate that the entire 'Transformation of Older Adults Day Services' project was fundamentally flawed. Why? Because at no point was proper consultative engagement entered into with those directly affected. That approach is unlawful in the context of the Equality Act 2010. Our lawyers studied our meticulous, time-lined collection of communications, minutes & emails & they agreed that the case had grounds. After all, a very similar precedent had already been set with the McHattie vs South Ayrshire Council judicial review (Jan 2021). The parallels with our situation with SBC & TDS were crystal clear to anyone outside of SBC. Yet, even SBC's internal legal team, including the Chief Legal Officer, apparently advised officials that the risk of facing a similar, successful legal challenge 'is unlikely for SBC'. Utterly incredible.

After a long wait, on Tuesday 20th September we received the judgment of Lady Carmichael who had presided over the judicial review. Her assessment of SBC's conduct is damning to say the least & she has judged the decision taken by the Executive Committee on 4th June 2019 to decommission TDS as unlawful. The complete judgment can be read here & it is indeed worth a read.

It is now blatantly apparent that the highest court of law in Scotland has judged that our perception of the truth is accurate.

Our summary is:

• The meeting held by an SBC official at TDS on 14th March 2019 was unlawful.
• The decision taken by the Executive Committee of the Council on 4th June 2019 was unlawful & has been instructed by Lady Carmichael to be 'reduced' (i.e. annulled).
• SBC has very clearly breached its statutory obligations under the Equality Act 2010.
• The Equality Impact Assessment process, legally obligated to be undertaken diligently & with genuine consultation of all affected parties, has been treated by SBC officials as a 'tick box' exercise.
• SBC's record keeping & documentation in relation to the associated statutory legal obligations has been highlighted as poor.
• Lady Carmichael states in her last paragraph 'I am conscious that the decision affected other services, and that the focus of these proceedings has been only on the lawfulness of the decision relating to the Teviot Day Service. I also grant declarator that the decision so far as relating to the Teviot Day Service was unlawful in respect that the council failed to perform its statutory duty under section 149 of the Equality Act 2010, and in respect that it frustrated the legitimate expectation of the petitioner to consultation.' This suggests to us that Lady Carmichael believes the decision to close other day services in the Borders, also taken on 4th June 2019, may well be questionable - we all know it is.

Where does this leave us? Currently we are awaiting a substantive response from SBC which will indicate precisely what actions are going to be taken to redress the unlawful decisions, but SBC must surely provide answer to the Borders communities who have a right to know why the travesty of Day Service closures has been unlawfully imposed on them & what is going to be done to rectify this.

As this is not the first time SBC has had high-profile & very serious judgments made against it in recent times, we would suggest that the Council should perhaps be seriously reviewing how it is conducting the process of decision making for proposals which may result in significant changes for sections of Borders communities. Care Villages & the outsourcing of Day Services for Adults with Learning Disabilities immediately spring to mind. Can the public have confidence that decisions in these areas are actually being made in accordance with SBC's statutory legal obligations? Why is it that, once again, public money in the Borders has been spent attempting to defend the indefensible. Lessons must be learned & Borders communities need to see changes at SBC which will prevent further breaches of public trust & legal obligations.

Whilst we have won a legal case, we will certainly not be resting until much needed older adult buildings based day services are once again operational in the Scottish Borders.

Planning for better

 No-one envisaged or wanted the start to 2021 we're all going through. Far from improvement, things have got a lot worse, we're back in lockdown and we're told to expect things to get worse before they get better. All this in the face of rolling out vaccines. It's clear no-one can accurately predict what's going to happen next and I doubt we would believe anyone who says they can anyway.

In the meantime, the predicament for carers and their families are not getting any easier and from Carers First group video calls, organised by Borders Carers Centre, we know that many carers are at breaking point as the result of lack of respite and the cumulative effect isolation is having on the 'cared for'. This is why BCC, on behalf of all carers in the Borders, ourselves, representing Teviot Day Service, and local Councillors have continued to lobby Scottish Borders Council officials to provide some form of services to alleviate the pressure, particularly on carers. As you probably know, our view is that this should have been in place months ago and the planning should have been done or at least started mid-2020.

Families in Hawick (and presumably elsewhere) received this communication earlier this month.

My, and others', initial reaction on receiving this was not positive for a number of reasons. It lacks detail, clarity and timescales. In other words, it tells you absolutely nothing. It has to be one of the poorest examples of communication I've seen. Worse still, it states '....we require to move to implementing emergency plans for operating in a pandemic.' It is dated 7 January and one wonders if the author has been in a time warp? We've been in a pandemic since March 2020 so why have the emergency plans not been conceived and acted upon some time ago? The letter also suggests that changes to individual care may take place but there is no indication of any form of consultation, contact or timescale. Consultation and appropriate communication are key aspects of the lobbying work BCC, TDS Support Group and other representative groups have been consistently stating must improve, not least because these are statutory requirements. Clearly there are SBC officials to whom this message is still not getting through. Quite simply, a communication like this is not good enough and can't be accepted without highlighting its flaws.

Aside from this, there are some glimmers of light. We are aware that some hours of respite have been offered to carers in some circumstances, long overdue but very much welcomed. This morning, we were represented on a group video call chaired by Robert McCulloch-Graham in the first stage of formalising a Carers Workstream which will hopefully be able to feed into and influence the Borders Health and Social Care Partnership's Strategic Planning Group. The formation of the Carers Workstream has long since been a necessity that BCC have lobbied for and it has representation from carers, BCC, Social Work and hopefully other relevant front line workers, the idea being to feed in the needs and views of carers and the reality of the 'coal face' directly to the senior level decision making process. Far too long have we endured uni-directional, top down decisions without any 360 degree feedback loop and that has resulted in complete disconnect between decisions being made by the Integration Joint Board/Strategic Planning Group and what is actually needed or is workable in practice. The formation of this Carers Workstream is a small but positive step, though very early days yet.

Hopefully by the next update, signficantly greater numbers of people will have been vaccinated and we will be in an improving situation.  Until then, stay safe and well.

'Stonewalling' - a speciality of those in charge of Health & Social Care at Scottish Borders Council?

First of all apologies for the lack of posts since April. As everyone knows all to well, this is no normal year. Hopefully the announcements of today (2 December) are the beginning of the end of the pandemic. However, the rest of this blog post isn't going to be quite so positive, so be warned.....

We continue to lobby on behalf of those whose need of day care services like Teviot Day Service has been highlighted like never before.The impact of Covid-19 has only served to  exacerbate these needs. Some of the worst hit include the elderly ('cared for') and their carers/relatives. The impact on 'cared for' has been all too obvious for those close to it, but perhaps not so obvious to others. It has not been a good time to be elderly and relying on care, for a variety of reasons:

• Care services have been impacted and day care services have been curtailed.
• An increased likelihood of being ejected from hospital too early for any ailment other than Covid-19. In fact in Scotland sadly, even with Covid-19 the elderly have been prematurely ejected from hospitals into residential care homes with devastating results.
• Isolation is a double-edged sword - supposed to protect the elderly from the ravages of Covid-19 but isolation undoubtedly results in deterioration in mobility, social engagement and mental stimulation to name a few issues.
• A deterioration spiral ensues which involves greater care requirements and, in many cases, an earlier than anticipated need for 24 hour care and a move to residential care.
• We have seen the passing of several previous TDS attendees during this difficult period and our thoughts and best wishes go out to their families.

We've all had to adapt many aspects of our lives over the past 9 months. Businesses, in particular retail and hospitality, have had to cope with restrictions never witnessed in our lifetimes. However, many have adapted and made their operations as safe as possible so that we can do, within guidelines, as many of the things we did before all this started. This brings me round to Day Services. During the total lockdown, nobody expected anything. Following a loosening of restrictions however, the Scottish Government's Cabinet Secretary for Health, Jeane Freeman, issued a communication in August, with an update in October, regarding the 'safe re-opening and delivery of building-based day services for adults'. Have a read of it for yourself here as there are key messages being issued to Councils in it:

• It reiterates the importance of day time support for 'cared for' and carers/families.
• It encourages Health and Social Care Partnerships to 'to continue to work together with providers and the people who use their services to assess these continuing needs and meet them in the most appropriate way'.
• It recognises that local areas have different decision-making structures but 'each local area should agree which multi-disciplinary group has responsibility for signing off risk assessments for individual services and communicate this with the services', emphasising that risk assessments and 'sign-off arrangements are well understood locally'.

Naturally, we have pursued SBC's Chief Officer for Health and Social Care, Robert McCulloch-Graham, repeatedly on this subject. There is no doubt that Mr McCulloch-Graham is a seasoned public sector professional (Google's great, isn't it?), with a variety of senior positions in his past career spanning the length and breadth of the UK. However, he is also a practiced expert in the art of 'stonewalling', a tactic often employed to deal with bothersome members of the community attempting to lobby, question or challenge. Our emails and enquiries often meet with silence, long delays and responses which consist of nothing more tangible than fresh air. In our repeated challenge of why SBC do not seem to be making any attempt whatsoever to re-open a much needed Teviot Day Service (in any form), our initial response (18 September) from Mr McCulloch-Graham was that 'we feel that to re-open day centres....would not be safe'. 

As that was clearly not an adequate response we followed up, expressing the dire need for the Day Service in some form or another, not just for the benefit of 'cared for' but crucially to provide much needed respite for carers/families - I haven't even touched on the impact on this group so far.

His next response (1 October) was to state 'both the size and the layout for the Katherine Elliot Centre will not comply with infection control measures due to lack of space and the inability to include a one way system for entry and exit.' So businesses up and down the country are able to modify their operations, procedures and premises to make them safe, but SBC are unable to do similarly for the Katherine Elliot Centre? In his reponse, Mr McCulloch-Graham provided no evidence of risk assessments or evidence of such having been attempted or done. Our trust level in the word of Mr McCulloch-Graham and his colleagues at SBC is such that we need to see evidence, otherwise our belief, frankly speaking, is that SBC are hiding behind Covid as an excuse to make zero effort to re-open Day Services. It doesn't take much to make us think that this fits in very nicely with SBC's original objective (already widely acknowledged) to close down every day service in the Borders.

We responded on 2 October, expressing our astonishment at Mr McCulloch-Graham's claims and urging him to convene a working group to include representation from all interested stakeholders (i.e. organisations such as Borders Carers Centre and TDS Support Group) to address the ongoing and escalating impact on 'cared for' and carers/families. We're still waiting on a response, despite follow up emails. Stonewalled again.

We've also written to Councillor Elaine Thornton-Nicol who was appointed as SBC's Dementia Champion earlier this year. She has also failed to provide any meaningful response to us (despite 3 follow up emails), though she did attend Border Carers Centre's most recent Carer's First (online) meeting on 12 November, to which Mr McCulloch-Graham declined to attend incidentally, presumably having far more important matters than the increasingly desperate plight of carers to attend to. On hearing just how bad the situation has become for many carers with absolutely no respite options and the resulting mental health and well-being impact, Councillor Thornton-Nicol expressed her anger at what she was hearing and promised to use her 'big voice' to 'shout, bawl and bang the drum' on behalf of all struggling carers in the Borders. Another 3 weeks down the line and I fear that Councillor Thornton-Nicol may have lost her 'big voice' as the silence is deafening.

In terms of the impact the lack of SBC activity is having on carers/families, it is in some ways even more traumatic than the impact on 'cared for'. A periodic phone call from an SBC employee asking how you are is absolutely no substitute for day services and respite, yet this is the extent of the measures SBC have taken since suspending remaining day services. 

Chat to anyone at Borders Carers Centre and you will very quickly get a picture of the reality faced by carers all over the Borders. I would challenge Mr McCulloch-Graham to spend some time dealing with the calls Borders Carers Centre staff are receiving every day.

If you've managed to stay the course in this rather downbeat blog, the summary is that SBC do not seem to care about the impact their decisions have on 'cared for' and carers/families. What other conclusion can be drawn from the experiences we continue to have with attempting to hold them to account for making decisions without proper consultation and engagement with relevant stakeholders? Engagement with stakeholders in order to define strategy and decisions is something they are obliged to undertake incidentally, according to Scottish Government Health and Social Care policy, yet there seems to be no true mechanism for making sure SBC execute their obligations properly.

On a positive note, in Hawick we continue to have support from local Councillors, in particular Councillors MacAteer, Marshall and Ramage, for which we are grateful. However, unless there is a more united front from a wider body of Councillors across the Borders to pressurise SBC officials, we will continue to encounter expert stonewalling tactics from Mr McCulloch-Graham and co. I'm sure everyone knows someone who is having to provide care for a loved one. As well as your sympathy and support, go that bit extra and lobby your Councillor wherever you are in the Borders. If you really get the bit between your teeth, lobby your MSP and MP too. It is the only way.

Teviot Day Service Status

It's been a while since our last post, but so much has happened and very few would say that they could have foreseen the situation the whole nation finds itself in right now. Teviot Day Service (TDS) was suspended on 18th March due to COVID-19 and before getting into further details of our update, we hope that everyone is staying safe and well. As a result of the pandemic, there can be no-one left in the country that doesn't realise the importance of and have the utmost appreciation for health, social and care workers, as well as all the other key workers on which society depends. Looking at our own situation as carers and relatives of elderly loved ones, where would we find ourselves without the continuing support of carers in particular? It is hard enough at present with the elderly confined to their homes and unable to participate in the services and activities they had access to before 'lockdown' but it would be so many times harder without the support of carers too - we truly appreciate your help and wish everyone well during these difficult times.

From the end of last year to February, SBC conducted social, personal and carer assessments with the attendees of TDS and their relatives/carers. Without the pressure and challenges to SBC from TDS Support Group, this exercise would not have been undertaken and TDS would most likely have been closed down by end January - that was Robert McCulloch-Graham's provisional 'decommissioning' date in the report presented to SBC's Executive Committee on 4th June 2019 (we've outlined our thoughts on that process in a previous post). Had SBC consulted properly with carers and relatives at the outset of the 'Re-imagining Day Services' project, as they are legally obligated to do, this exercise would and should have been conducted before the preparation of the report presented to Executive Committee. We can only speculate as to why carers/relatives have not been properly consulted with to determine whether closure of Day Services in the Scottish Borders is the correct strategy. What we do know is that the outcome of the assessments are universal in their recommendation that our loved ones continue to absolutely require TDS as there is currently no alternative, equivalent or better service available in Hawick. This is something we have stated and re-iterated constantly, as have several of our local Councillors, to SBC officials since we first became aware of SBC's intentions in March 2019. These aren't just our words - here are just a couple of examples of the conclusions taken directly from some of the assessments conducted:

There is no alternative other than TDS which can provide this level of support at this moment in time. 

It is my recommendation at present that <attendee> remains at TDS as there is not a suitable alternative. 

If the opportunity to attend TDS were to be removed, the risks to both <attendee> and <relative> would dramatically change as this level of support and stimulation could not be provided in the community. The LAC (Local Area Co-ordinator) has stated that there are no services within the town that would replicate the type of specialist support required by <attendee>.

The significance of these conclusions cannot be underlined enough - these are the conclusions of SBC employees who work in the Hawick community and have conducted these assessments. Clearly there is a significant disconnect between those based at SBC HQ and SBC professionals who are actively involved in social care in Hawick. Why weren't these professionals engaged and consulted with much earlier in the project, rather than only when SBC management officials had no choice due to the pressure of our small campaign group identifying the fundamental flaws and oversights in the 'Re-imagining Days Services' project. It is a travesty that 6 of the 7 Day Services in the Scottish Borders have already been closed and perhaps it is significant that the only one remaining is TDS, the only one where relatives/carers have gathered together as a group and challenged SBC on their statutory obligations to properly consult with those impacted before making decisions to close down services.

We would actually like to hear from people elsewhere in the Borders who have been adversely affected by the closure of the Day Service in their area. Please do email us as a precedent has already been set elsewhere in Scotland for successfully challenging a local authority which closed down a Day Service and were found to have been in breach of their legal and statutory obligations. If you know of someone who has been adversely affected by a Day Service in the Borders, please send this on to them and ask them to contact us.

Until the next post, stay safe and well everyone.

Decision making at Scottish Borders Council

One of the key drivers for 'Day Services Transformation', Scottish Borders Council's project which aims to 'decommission' (i.e. close down) Day Service facilities throughout the Scotish Borders is financial cost savings. One of the key people involved in the project has denied this publicly, although others involved haven't. And there we have our first point of mistrust - an inability to be honest with the general public. We all know that Councils are suffering from increasing demands on services which results in ever increasing demands on finances. It is therefore understandable and, in fact, imperative that Councils review where money is being spent in order to establish if and how cost savings and efficiencies could be made.

However, let's not try and tell us that it isn't about money. SBC's 'Day Service Transformation' report (you have to scroll to page 167 for this) by Robert McCulloch-Graham (Chief Officer - Health and Social Care) was presented to SBC's Executive Committee on 4 June 2019 (15 minutes on the agenda) and recommended the Executive Committee:

(a) notes the expansion of the Local Area Co-ordination to all areas of Scottish Borders; and
(b) agrees to the decommissioning of individual Day Services when suitable alternatives that meet assessed needs are identified following the introduction of the new model of Local Area Co-ordination for older adults.

One of the key points of the report is Section 1.3 'The 2017-18 Financial Plan approved by Scottish Borders Council on 9 February 2017 outlined efficiencies and the need to "review current Day Services and staffing models". This was re-affirmed in the 2018-19 Financial Plan. This modernised approach aims to provide better services focussed on the needs of individual people whilst also providing greater efficiency.'

So it is about money. The focus on individual needs would be laudable were it wholly sincere, which it isn't. Self-directed care is being used as a sweeping broad brush to justify the decommissioning of Day Services. We'll explore that one in another blog post.

The recommendations above were carried unanimously by the Executive Committee, based on the report.  We have a number of concerns regarding this whole process of crucial decision making at SBC.

Democratic decision making?
You'd be forgiven for thinking that recommendations such as those above would be voted on democratically with involvement from Councillors from all areas. After all Councillors are elected by us, the general public, to represent us and ensure they take forward our views, opinions, needs and requirements so that balanced, democratic governance takes place. Unfortunately, the way SBC's Executive Committee currently works, not all Councillors are able to be on the Executive Committee. In particular, 'opposition' Councillors (i.e. those Councillors not aligned to the ruling administration) are not invited to be part of the Executive Committee. Doesn't sound very democratic, does it? Apparently it's legal to operate this way, but the end result of this approach is that the ruling administration invariably passes the recommendations it wants without opposition.

At TDS Support Group, we're no political or local government gurus and we're happy to be corrected on anything we say that isn't correct. However, this is the situation with the way SBC currently operates.

How good or accurate is the information being presented for decision making?
Of course the way any organisation works, in order for sound decision making to take place, there is a reliance on reports, the detail and accuracy contained in them. People are appointed to positions within an organisation based on their proven skills and experience (hopefully!) and therefore there has to be trust and confidence in what they say and present. But equally there has to be sound governance to ensure that decisions can be made with real confidence that they are the right ones. When we're talking about Council decisions, these often affect people lives. Sometimes the real impact of a decision doesn't become apparent until some time has elapsed (often by which time those who have recommended or made the decisions have moved on to pastures new). Where is the governance and accountability to ensure that recommendations can be independently verified as being correct (or at least likely to be right) and are not subject to conflict of interest, incompetence or something else which might result in misguided decisions?

This is a whole subject in its own right, but coming back to the 'Day Service Transformation' report, there is no cross-referencing to evidential papers or research to back up some of the information being presented - it is simply presented as fact. We'll come back to this on another blog post.

How well equipped or experienced are Executive Committee members
If something you're being asked to make a decision on isn't in your field of knowledge or experience, it would seem sensible to ensure that you're given as much background and detail as possible so that you can drill down to a level where you're comfortable that recommendations you're being asked to support are right. Based on the situation with the 'Day Service Transformation' project (which you may also hear called 'Re-imagining Day Services' or simply 'Tranformation'), this doesn't seem to be the case. So if the level of detail isn't made available to members of the Executive Committee, how much reliance can be placed on the right decisions being made? Very little and operating in this manner, decisions may as well not be passed through the Executive Committee. We respect the honesty and candidness of one Councillor on the Executive Committee who, after attending one of our Support Group meetings stated that he would not have supported the recommendations if he had known how the project was being executed.

Our journey in opposing SBC's desire to decommission Day Services in the Borders has been a real eye opener and we'll continue to share our experiences with you.

Why do we exist?

On 14th March 2019, Scottish Borders Council's Programme Manager (Day Services Review), Michael Curran, held a meeting with Teviot Day Service attendees & their relatives/carers & announced proposals to decommission Day Services throughout the Borders & enter in a period of engagement with attendees to look at alternatives. The justification for this move was two-fold:

• A decrease in the number of people attending day services.
• A pilot exercise conducted in Eyemouth (Berwickshire) relating to 4 people attending a local day centre.

At this meeting, Mr Curran publicly stated that no further referrals to Teviot Day Service would happen in the interim period (a statement which was later retracted) & also stated that the 'transformation programme' was not about money.

Since that day, we created the Teviot Day Service Support Group which comprises relatives & carers of those who attend Teviot Day Service. We oppose & are campaigning against the decommissioning of any Day Services as we believe these are not only absolutely necessary but provide a service which is a statutory Health & Social Services obligation on Scottish Borders Council. Our meetings are well attended by relatives & carers, local Councillors & representatives from third sector support organisations Borders Carers Center & Borders Care Voice.

The majority of those who attend Teviot Day Service are very elderly & suffer from forms of Dementia. They have significant care requirements & the relatives & carers who look after them also require, & are entitled to, respite.

It is our opinion that the aspects of Scottish Borders Council's 'Re-imagining Day Services' project which aim to decommission Day Services are ill-conceived, lack provable evidence & have been appallingly poorly executed to date in terms of consultation & communication with relatives & carers. We are willing & have attempted to work with Scottish Borders Council to improve Day Service provision, not abandon those in the very twilight years of their life when they really need care nor deny their carers the right to some respite. It is also our duty as a Support Group to ensure Scottish Borders Council employees managing the 'Re-imagining Day Services' project do so in accordance with their legal & statutory obligations & are held accountable for their actions & decisions.