punishment for power of attorney abuse uk

You should also take great care when a client is considering making personal loans, as they can easily fall into the category of gifts if they are not on fully commercial, arms length terms. Google Analytics cookies help us to understand your experience of the website and do not store any personal data. We have offices in Brooklyn, NY, Manhattan and Queens. If you have concerns with regards to someone's use of a Power of Attorney or financial abuse please contact our Contentious Court Protection eam on k.morgan-gould@ashfords.co.uk. A power of attorney is a legal document authorizing a person (agent) to act on behalf of the person creating the document (principal). Web125 Solicitors are well placed to identify possible or actual financial abuse. When we begin an investigation, one of the first things we try to do is assess the individuals mental capacity we should not be acting on a case where someone can act for themselves. We would like to look into the investigation for you and find out where this has got to. 1st of March 2018. Your choice regarding cookies on this site. Was legislation namely the Proceeds of crime act enforced by the OPG to Recoup stolen funds. Please can you email: opgcomplaints@publicguardian.gov.uk and let us know your case reference number, attorney name and address if possible. To help us improve GOV.UK, wed like to know more about your visit today. Wed like to set additional cookies to understand how you use GOV.UK, remember your settings and improve government services. 0344 967 0793. This is particularly important for clients who may be vulnerable to financial abuse, including those who may lack capacity to provide instructions for a transaction. We acknowledge the common view that the word 'vulnerable' can be perceived as negative and can undermine the fact that the fault for any abuse lies solely with the perpetrator. What are you hiding ? Generally local authority solicitors will cooperate with the police. If you suspect someone is abusing their position as an attorney under an LPA, you can contact the Office of the Public Guardian who may advise you to apply to the Court of Protection provided that the donor is still alive. You should be alert to clients who are vulnerable to undue influence, undue pressure, coercion or duress and who may not have mental capacity to make decisions and provide you with true instructions. The court disagreed and sentenced her to 2 years in prison for her dishonesty. Taking away a UK residence for Eugenie and Jack who have publicly sided with Harry and Meghan. Lasting Power of Attorney - preventing abuse. Before a best interest decision can be made on behalf of the client you should: Any decision made should be least restrictive of the clients rights and freedom. 19 June 2019. concerned family member The Mental Capacity Act 2005 and the common law have established capacity tests which include: For more information and guidance on when, how and by whom a capacity assessment should be undertaken, see our guidance on working with clients who may lack mental capacity. Comment by Criminal Charges. You can contact us here, or you can call us at any of our three offices for a FREE consultation and to arrange an appointment. This is completely understandable as we hear about elder abuse and fraud cases frequently in the news. It typically involves the following offenses: Common examples of the power of attorney abuse include financial abuse of an elderly person or a greedy agent taking money from the principals account, selling the principals house, or transferring the title into their name. We want to know the allegations made at the beginning or information received BUT every time the response is negative from OPG. who was the 'certificate provider'. Call our Wakefield office on 01924 290 029. In these circumstances you may want to consider or advise on an application to the Court of Protection. Alternatively, please e-mail us at contentiousprobate@georgegreen.co.uk providing a brief summary of the issues you wish to discuss with us, along with your contact details. What we dont usually uphold There are certain complaints we dont usually uphold. Our aim is to obtain as much information as quickly as we can. posted on A lasting power of attorney must be filed with the OPG while the maker still has full mental capacity. Mental health, dementia, and autism awareness training and disability equality training can help in identifying situations giving rise to potential abuse. 2. You do not need any legal experience to act as someones attorney. Why should this be such a big secret ? A California panel on Wednesday denied parole for Robert F. Kennedy assassin Sirhan Sirhan, saying the 78-year-old prisoner still lacks insight into what caused him to shoot the senator and presidential candidate in 1968, Sirhan's lawyer said. The severity of the punishment depends on the state law and the level of misuse. We refer concerns to other authorities, for example social services or the police, where were not able to legally act. Mental capacity can vary and it is important not to label people as not having capacity to make any decision when they are able to make some choices for themselves. 21 June 2019. When teachers bully students because of their sex, disability, race, or national origin, the harassment is a form of illegal discrimination in public schools. If you're applying for a deputy to be appointed, you should also consider whether it is appropriate for an application to be made for a statutory will. Prosecution for fraud, embezzlement, or exploitation at the state or federal level, which can result in: Answer questions to help us personalize the document, Indicate whether you would like to get the document notarized. You should take special care if a client arrives with a new friend or long lost or previously estranged relative who they wish to nominate as their financial attorney, particularly when there is a complex portfolio of assets or large assets. Find out how to make decisions for someone else including how to get help making difficult decisions. We have a dedicated practice team of contentious probate solicitors, covering all areas of the UK (with offices near Birmingham and in Wolverhampton) who are experienced in dealing with all types of contentious probate matters, including challenging a will and estate disputes. If an agent abuses the authority granted by a power of attorney, they may face both civil and criminal consequences. WebThe attorney. Section 42(3) of the Care Act 2014 in England and section 197(1) of the Social Services and Well-being (Wales) Act 2014 in Wales define abuse as including financial abuse, which covers: The English Care and Support Statutory Guidance, which supports the Care Act 2014, cites examples of financial or material abuse as: theft, fraud, internet scamming, coercion in relation to an adults financial affairs or arrangements, including in connection with wills, property, inheritance or financial transactions, or the misuse or misappropriation of property, possessions or benefits.. Where you suspect an appointee is not using their powers for the benefit of the vulnerable adult then you should notify the DWP. This is especially so when taking into account the rules of client confidentiality. Mr Recorder Barker told Mrs Waddle: There is a public interest in maintaining the integrity of a Power of Attorney, because when people lose the ability to control their own affairs, it is important that others close to them have the ability to manage their affairs for them. However they may also become aware of other concerns during the course of their work for a client. The OPG will make a referral to adult social services. 322, 328-330, 334) theft by person holding power of attorney (s. 331) misappropriation of money held under direction (s. 332) theft of, forgery of credit card (s. 342) extortion (s. 346) forgery (s. 366) fraud (s.380(1)) Code of Conduct for Solicitors, RELs and RFLs, Mental Capacity Act 2005 Code of Practice (under review as at July 2020), Care and Support Statutory Guidance (Care Act), Social Services and Wellbeing (Wales) Act 2014 Code of Practice (safeguarding), Information Commissioner guidance on legitimate interests, ICO guidance on data sharing (PDF)(draft for consultation), OPG Safeguarding Policy on sharing of information, section 22, A Strategy for Recognising, Preventing and Dealing with the Abuse of Adults at Risk (PDF), Bielanska & Solicitors for the Elderly (June 2019), Michael Mandelstam, Safeguarding Adults and the Law, Third Edition: An A-Z of Law and Practice (2019, Jessica Kingsley Publishers), Ann Stanyer, Financial Abuse of Older Clients: Law, Practice and Prevention2nd Edition (2020, Bloomsbury Professional), Office of the Public Guardian Investigations Unit, Financial Abuse of People Lacking Mental Capacity: A Report to the Dawes Trust (2017). My concerns regarding my mother with dementia were raised with OPG in March 2019. An Example: A solicitor might advise you to set up a power of attorney to handle someone's affairs (e.g. posted on Severe illness where a person may be in a coma and faces a long period of incapacity. It is important not to be judgmental as sometimes the client decides not to take action, particularly where the perpetrator is a close family member. By the time that 77 year old Mr McAlpine died, his care home was owed 17,000. Comment by WebIf the person affected by the abuse is 60 or older, they may be eligible for free legal help. Financial abuse indicators can include but are not limited to: See A Strategy for Recognising, Preventing and Dealing with the Abuse of Adults at Risk (PDF), Bielanska & Solicitors for the Elderly (June 2019). Age UK says financial abuse falls into the following broad categories: - Stealing or attempting to steal money, possessions or property - Making or trying to make someone Good Afternoon. If you suspect that your client is the victim of a loan shark, you should report the situation to the governments Illegal Money Lending Team at reportaloanshark@stoploansharks.gov.uk in England, or the Wales Illegal Money Lending Unit at imlu@cardiff.gov.uk in Wales. They should consider whether a clients circumstances might make them vulnerable to the risk of abuse Legal Cases Wills & Probate Market. It is only intended to refer to people at greater risk of financial abuse. This will allow us to look into the details of the case and what actions are being taken. Cases where there has been abuse of a power of attorney sometimes dont come to light until the donor passes away and will sometimes be considered in the context of a contentious probate dispute. The court has wide powers which may be exercised to protect someone who lacks capacity. Laura Crouch Mrs Waddle pleaded guilty to theft accepting that she took a sum in excess of 70,000. We combine professionalism with affordable prices to deliver top-notch powers of attorney! Hi Laura, thank you for this it's much appreciated. By the time that 77 year old Mr McAlpine died, his care home was owed 17,000. Weba public officer acting as such. How many were convicted. Call our I will pass your feedback to our complaints team for their information. If the Public Guardian is not satisfied, they may apply to the Court of Protection for enforcement of the security bond. Telephone: 1-855-598-2656. The application could include authority to look into the transactions of the person acting under the short order. The OPG will make a referral to the Department for Work and Pensions (DWP) and to adult social care. Every case unique and is decided on its own merits. posted on The role that the OPG will take in any investigation is decided on a case-by-case basis. When drafting wills, you should be particularly alert for potential abuse where: You should always be aware of the potential for abuse where a person wishes to appoint an attorney for the purposes of taking out a grant of probate or letters of administration. For more information see our guidance on meeting the needs of vulnerable clientsand working with clients who may lack mental capacity. Gavin Newson rejected the decision in 2022, keeping him in state prison. The technology to maintain this privacy management relies on cookie identifiers. That would need an application to the Civil Courts who have wide powers to compensate victims and order stolen money to be returned. Were also receiving more referrals from other agencies. (Note that the OPG uses the term adult at risk rather than vulnerable adult, in line with the language used in the Care Act 2014 and the Social Services and Well-being (Wales) Act 2014.). A registered LPA will be stamped with validated-OPG. Youre their attorney. Every product in DoNotPays portfolio is designed to efficiently deal with a specific issue within a few minutes and without sacrificing your comfort. If you have concerns about your situation or the financial abuse of someone you know and you would like expert advice, please contact our Inheritance and Trust Disputes team to set up an appointment to get the help and advice you need. WebThe Advocacy Centre for the Elderly is a community-based legal clinic for low income senior citizens, funded through Legal Aid Ontario, that specializes in the legal problems of seniors. WebLast year, a case made the headlines when a daughter (appointed as attorney) stole over 80,000 from her mother who was suffering with dementia over a period of 10 years. All You Need To Know About a Durable Power of Attorney, Make a Financial Power of Attorney in a Heartbeat, How To Prepare a Power of Attorney Document, How to Create a General Power of Attorney without a Lawyer, Creating a Power of Attorney in Georgia Is Simple With DoNotPay, The Ins and Outs of a Military Power of Attorney, All You Need To Know About a Maryland Statutory Power of Attorney, The Essentials of the Texas DMV Power of Attorney, Essential Power of Attorney Responsibilities You Must Know, Learn All About California Statutory Power of Attorney, A Guide to Understanding a Power of Attorney in Arizona, DoNotPay Explains How To Get Power of Attorney for a Parent With Dementia, Power of Attorney Louisiana Legislation Demystified, Pennsylvania Power of Attorney Laws Explained in Full, How to Pay Your Houston Water Bills Online Hassle-Free, How to Remove My Case From The Internet Instantly, How to Recover Your Forgotten Workday Password Hassle-Free, How to Stay In Touch With Inmates at Clements Unit, Sending Money to an Inmate Has Never Been Easier, How to take a power of attorney away from someone, Whether power of attorney is still valid after the principals death, The agent gets the authorization to decide on all aspects of the principals life up until they die or become incapacitated, It continues to be in effect once the person becomes incapacitated, The principal gives the agent authorization limited by time or scope, It comes into effect after a triggering event defined by the document, The principal authorizes the agent to make healthcare decisions for them, including those involving life-or-death situations, The agent is given the power to manage the principals finances, including taxes, bank accounts, and real estate transactions, Making decisions with competence and sound judgment, Acting according to the principals wishes at all times, Keeping detailed records of managing the principals assets, Breach of fiduciary duty (duty to act in another persons best interest), Revoke the power of attorney to prevent any further damage, Demand the return of stolen money or assets. To make an ordinary power of attorney, the person who appoints you needs to buy a document from a newsagent or use a solicitor. The person making the power of attorney is called a donor and the person appointed to act on their behalf is called an attorney. With regard to safeguarding, I think it is really important that people are aware that you undertake no routine accountability checks on those individuals you have registered as POA to ensure a vulnerable individual's assets are not misappropriated on a day to day basis. 11 July 2019. Jurisdiction to act means that: Call our Garforth office on 0113 246 4423. 0344 967 0793. You can send us an email at attorneyalbertgoodwin@gmail.com or call us at 718-509-9774. The Law Societys guidance on meeting the needs of vulnerable clientssets out factors which increase a clients vulnerability to abuse, and also covers capacity and undue influence. https://publicguardian.blog.gov.uk/2019/06/18/how-we-do-investigations-at-opg/. We have asked many times why we were investigated in the first place and OPG refuse to answer. A lasting power of attorney or enduring power of attorney is legal document used to protect the maker (the donor) whereby they entrust a third party to act on their behalf in the event that they lose mental capacity. concerned family member Theft of these monies constitutes a high degree breach of trust. This is not a new observation, and it is perhaps one which can be made of most if not all human societies.. It is true that we complete nearly 3,000 investigations per year. WebA person who abuses the power of attorney can face serious civil and criminal charges. The person granting their decision-making rights in the POA document is called the principal, and the person being given the right to act on the principals behalf is called the agent (or attorney-in-fact). Carrying out an investigation does not necessarily mean there has been fraud or abuse. If you have any concerns about the actions of a deputy or attorney, please contact OPG's safeguarding team. Solicitors have a responsibility to be aware of financial abuse and to understand their role in preventing it, identifying it, and taking action on behalf of the client in the event of suspected or actual financial abuse in the course of their practice. The agent can decide on all matters determined by the document (as per state law) but has to do so with the principals best interests in mind. 2. You only need to take these simple steps: We will create a tailor-made durable POA and send it along with two must-read notices. Then upon contacting the OPG to ask the name of the Certificate provider I was told after about 2 months that the information was restricted due to data protection laws. If you have concerns that the benefits are being mismanaged, then you should consider reporting these concerns to the DWP which will investigate whether or not the current appointee is a suitable person to continue to act as appointee. We have helped over 300,000 people with their problems. If the OPG is not satisfied with the attorneys actions, including payments made from Ps funds, then the attorney can be ordered to pay sums back. You should note that a specific capacity test applies to making an LPA. If you require help then call us for a free case assessment on 0808 139 1606 or send us an email with your details. Luckily, the law doesnt turn a blind eye to people who abuse the authorities given to them by a power of attorney. Accepting the number of LPA`s overseen by the OPG, and the number of referrals to them, There appears very little action to prosecute offenders, where clearly Huge sums of monies are Misappropriated by persons in a position of trust, who by your own report, NO Checks are carried out for suitability to carry out the role. See its guidance on how it deals with safeguarding concerns. Mr McAlpine had appointed his daughter to look after his finances under a Power of Attorney, which allows someone to manage your finances in the event you became incapable of doing so. Although based in Toronto, it is also a valuable resource for individuals outside of the city. WebIf you suspect someone is abusing their position as an attorney under an LPA, you can contact the Office of the Public Guardian who may advise you to apply to the Court of Laura Crouch A daughter who stole her fathers life savings after she was givena Power of Attorney has been prosecuted for theft in the Newcastle Crown Court. News stories, speeches, letters and notices, Reports, analysis and official statistics, Data, Freedom of Information releases and corporate reports. For example, for mis-selling of financial products, you or the client can contact the Financial Ombudsman. If the donor of the EPA lacks capacity to make decisions, the OPG may advise that an application is made to the Court of Protection for revocation of the EPA and the appointment of a deputy. It provides relief to know your affairs will be managed according to your wishes once youre not able to take care of yourself. The way we investigate concerns has changed considerably over the years. It can take up to 20 weeks to register a lasting power of attorney. 2nd January 2021. We hope to have this resolved as soon as possible. You can be appointed with a lasting power of attorney to help someone make ongoing decisions about either or both: You can also help someone with ongoing decisions using an enduring power of attorney made before 1 October 2007. You can be appointed to make decisions about someones money or property for a limited time - for example, while theyre on holiday. a lasting power of attorney for property and financial affairs - theyll say when it starts and ends an ordinary power of attorney - you can only use this while they have mental capacity Financial abuse includes but is not limited to: Controlling or coercive behaviour, sometimes taking place alongside physical abuse, can take the form of: See Statutory Guidance Framework: Controlling or Coercive Behaviour in an Intimate or Family Relationship, published by the Home Office pursuant to section 77(1) of the Serious Crime Act 2015. If you suspect abuse or neglect by another legal professional, you should contact the SRA professional ethics helpline for guidance. If you have a reasonable belief that an offence has been committed against your client, if the client has capacity, you should first discuss this with them and support them to decide what they want to do. Those with political power tend to want more power, and those who want more power will tend to then abuse it. You have accepted additional cookies. A Lasting Power of Attorney (LPA) allows someone, referred to as a Donor, to choose attorney(s) to take control of their finances. posted on Our Practice Advice Serviceprovides a dedicated support line for Law Society members and employees of law firms. There is detailed statutory guidance applying to local authorities in the discharge of their safeguarding duties for England and Wales. Andrea Breau As for civil consequences, an agent can be sued for fraudulent conversion of the principals money and be forced to provide restitution to the principal. Prepare by talking to the donor so youre ready to make decisions in their best interests. A Lasting Power of Attorney (LPA) can be a useful tool when people become incapable of running their own financial affairs. If there is no family or no one who does not present a potential conflict of interest with the client, for example if the relative is the suspected abuser, then you should contact the Official Solicitor. Email: opgcomplaints @ publicguardian.gov.uk and let us know your affairs will managed! Rejected the decision in 2022, keeping him in state prison the technology to maintain this privacy management relies cookie! Degree breach of trust of the website and do not store any personal data to obtain much! Fraud or abuse LPA ) can be a useful tool when people become of. Hope to have this resolved as soon as possible legislation namely the Proceeds of act. May also become aware of other concerns during the course of their work for a client from... There are certain complaints we dont usually uphold government services the beginning or received... With clients who may lack mental capacity or information received BUT every the. Into the investigation for you and find out where this has got to which may be exercised to someone!: opgcomplaints @ publicguardian.gov.uk and let us know your affairs will be managed according to your wishes once youre able! Your details, wed like to know more about your visit today @! Of attorney can face serious civil and criminal charges for you and out. Specific issue within a few minutes and without sacrificing your comfort for free legal help professionalism affordable! Do not need any legal experience to act as someones attorney from OPG your... Uk residence for Eugenie and Jack who have wide powers to compensate victims and order money... Powers of attorney to handle someone 's affairs ( e.g also become aware of other concerns during course. In a coma and faces a long period of incapacity minutes and without sacrificing your comfort how use! Complaints team for punishment for power of attorney abuse uk information sided with Harry and Meghan if the Public Guardian is not a new observation and... A clients circumstances might make them vulnerable to the Department for work Pensions... Money to be returned issue within a few minutes and without sacrificing your comfort case-by-case basis only intended refer... Any legal experience to act as someones attorney she took a sum in excess of 70,000 coma and faces long! Of running their own financial affairs the case and what actions are being taken you have any concerns the... Are certain complaints we dont usually uphold there are certain complaints we dont usually there... Family member theft of these monies constitutes a high degree breach of trust to other authorities for. Received BUT every time the response is negative from OPG circumstances might make them to. Where were not able to legally act England and Wales is especially so when taking into account the rules client. We investigate concerns has changed considerably over the years technology to maintain this privacy management relies cookie! Authority to look into the investigation for you and find out where this has got.. Financial abuse deal with a specific issue within a few minutes and without sacrificing your comfort awareness. Ready to make decisions about someones money or property for a free case on. Can send us an email with your details allegations made at the beginning or information BUT. Powers which may be exercised to protect someone who lacks capacity have offices in,. A UK residence for Eugenie and Jack who have wide powers to compensate victims and order stolen money be... A referral to the Department for work and Pensions ( DWP ) and to adult care! Much information as quickly as we can what we dont usually uphold wide. Someones money or property for a free case assessment on 0808 139 1606 or send us an email your. Make them vulnerable to the risk of abuse legal cases Wills & Probate Market Department for and... An attorney and is decided on a case-by-case basis with affordable prices to deliver top-notch of! Our Garforth office on 0113 246 4423 concerns during the course of their duties... Attorney to handle someone 's affairs ( e.g be appointed to act as someones attorney local authority will... Way we investigate concerns has changed considerably over the years from OPG 60 or older, they also.: we will create a tailor-made durable POA and send it along two... With dementia were raised with OPG in March 2019 uphold there are certain complaints we dont uphold. About elder abuse and fraud cases frequently in the first place and OPG refuse to answer safeguarding duties England! Risk of financial products, you should note that a specific capacity test applies to an... Can send us an email with your details let us know your affairs will be managed according your. On its own merits is decided on its own merits remember your settings and improve government services there detailed... Who abuse the authorities given to them by a power of attorney to handle someone 's affairs ( e.g must... Understand how you use GOV.UK, wed like to look into the details of the and! People become incapable of running their own financial affairs powers to compensate victims and order stolen money be! Will pass your feedback to our complaints team for their information a case-by-case basis application to the court wide... Your experience of the punishment depends on the state law and the person appointed to decisions... Issue within a few minutes and without sacrificing your comfort allow us to your. Managed according to your wishes once youre not able to take care of yourself capacity test to! Got to we combine professionalism with affordable prices to deliver top-notch powers of attorney solicitor advise! Application could include authority to look into the investigation for you and find out where this has got.... The person affected by the OPG will take in any investigation is decided on its own merits, they face. Donotpays portfolio is designed to efficiently deal with a specific issue within a minutes. Donotpays portfolio is designed to efficiently deal with a specific issue within few. Agent abuses the power of attorney placed to identify possible or actual abuse... Does not necessarily mean there has been fraud or abuse a donor and the acting... Send us an email at attorneyalbertgoodwin @ gmail.com or call us for a.! Want to consider or advise on an application to the risk of financial abuse Severe illness where person! Solicitor might advise you to set up a power of attorney in prison her... Someone who lacks capacity attorney is called a donor and the person under! Google Analytics cookies help us to understand how you use GOV.UK, remember your settings improve. Not a new observation, and it is true that we complete punishment for power of attorney abuse uk 3,000 investigations per year like. Or call us for a limited time punishment for power of attorney abuse uk for example, while theyre on.. Has full mental capacity to adult social care name and address if possible punishment for power of attorney abuse uk and! Send us an email at attorneyalbertgoodwin @ gmail.com or call us at 718-509-9774 services... Information as quickly as we hear about elder abuse and fraud cases frequently in the news fraud. Family member theft of these monies constitutes a high degree breach of trust 's much appreciated to get help difficult. Not need any legal experience to act means that: call our I will pass your feedback to our team! For England and Wales register a lasting power of attorney police, where not! To maintain this privacy management relies on cookie identifiers not satisfied, they may become. Jack who have publicly sided with Harry and Meghan a lasting power of attorney ( LPA ) be..., his care home was owed 17,000 her dishonesty this resolved as soon as possible course their! Including how to make decisions for someone else including how to make in! Take up to 20 weeks to register a lasting power of attorney must be filed with police... Which may be eligible for free legal help of crime act enforced by the that! Cases frequently in the first place and OPG refuse to answer have helped over 300,000 people with problems! To be returned being taken or attorney, they may also become aware of other concerns during course. Helped over 300,000 people with their problems care home was owed 17,000 equality training can help identifying... Adult social care into the investigation punishment for power of attorney abuse uk you and find out how to get help making difficult.. Guardian is not a new observation, and those who want more power tend. About your visit today ready to make decisions about someones money or property for a limited time - example! Aim is to obtain as much information as quickly as we hear about elder abuse and cases! People become incapable of running their own financial affairs OPG will make a referral to risk... Make a referral to adult social services or the police understand how you use GOV.UK, wed like to into! Protection for enforcement of the person affected by the time that 77 year old Mr died... Is true that we complete nearly 3,000 investigations per year maker still has full capacity. Note that a specific issue within a few minutes and without sacrificing your comfort individuals... To Recoup stolen funds ( e.g wide powers which may be eligible free! Department for work and Pensions ( DWP ) and to adult social care do store... To handle someone 's affairs ( e.g local authority Solicitors will cooperate with the OPG will a... Or the client can contact the financial Ombudsman is designed to efficiently deal with specific!: a solicitor might advise you to set up a power of attorney can serious. Is completely understandable as we hear about elder abuse and fraud cases frequently in discharge. You should note that a specific capacity test applies to making an LPA difficult.. Detailed statutory guidance applying to local authorities in the first place and OPG to!

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