Research is increasingly being conducted by multi-stakeholder teams which include the researchers themselves, funding authorities, industry collaborators and community stakeholders inside and outside universities, all of whom have dynamic requirements relating to research data, research artefacts and products, and published outcomes. While the physical location of electronic research resources is of decreasing importance, control and ownership, as reflected in intellectual property policies and ethical requirements, have become highly contested within several communities. Such issues become even more complex when dealing with emergent participatory modes of e-Research, which influence:
·Empowerment of participants in the research.
·Recognition of different ways of researching.
·Institutional commitment to the long-term maintenance of a research repository.
·Adaptive research teams which are comfortable with electronic interactions.
·New legal ownership and access rights, and terms and conditions of use.
This paper deliberately focuses on the challenging area of participatory e-Research in order to surface the widest possible range of issues. It is designed to explore governance frameworks that can be applied in new e-Community contexts, and to identify the user needs of participants. It forms part of a new paradigm, which stresses the importance of facilitating participation, by addressing issues which arise about the new management principles required for the authenticity, accessibility, disposition and preservation of electronic research resources for multiple purposes.
The prime focus of the paper will be an investigation as to how well repositories and archival services, as they are presently constituted, meet the needs of communities. It will discuss issues including: empowerment, research frameworks, design and methods; and how to conduct ethical research with communities, including protocols, intellectual property, ownership of research data and of outcomes.
e-Research, Community-based research, research protocols
New approaches and structures
This paper describes some of the work undertaken as part of a Participatory e-research Project by the Centre for Community Networking Research at Monash University. It explores the practice of community participatory research in the context of the development of, and attitudes to, new e-research frameworks being promoted within Australian universities. Monash University is used as a case study because of its commitment to encourage the use of e-Research techniques and repositories by multidisciplinary research teams (see Treloar & Harboe-Ree 2008)
While issues associated with legal, ethical and cultural frameworks have been recognised and discussed in relation to their ability to hinder the take-up of e-Research infrastructure (see, for example, Denison et al 2007), emergent participatory modes of research raise a range of further issues relating to the empowerment of participants in the research, and recognition of quite different ways of researching, for example, of working with indigenous Australian communities.
With regard to e-Research infrastructure, these issues have potential implications for:
-institutional commitment to the long-term maintenance of repositories to support continued data storage and curation,
-adaptive research teams which are comfortable with electronic interactions,
-new legal ownership and access rights, and terms and conditions of use, and
-ethics and ethical frameworks.
e-Research repositories are relatively new structures with few precedents other than traditional repositories to guide their future. If Monash is to be successful in encouraging the use of e-Research techniques and repositories by multidisciplinary research teams, it will need to review the relevant governance frameworks, policies and standards in the light of the above issues.
There is a well-documented trend to increased collaboration in scientific research, with an emphasis on the sharing of, and access to, research data. It has developed at least partially in response to the increasing complexity of research, large and expensive research tools, an increasing interdisciplinarity, and an increasingly problem-oriented approach to research (National Research Council 2001, David 2004). In addition there is a growing perception that the outcomes from publicly-funded research, defined not only as publications but also as the data produced or collected along the way, should be available to the public (Arzberger et al 2004).
These trends have created a demand for accessible data repositories and tools to facilitate data access, storage, searching, and retrieval (David 2004). This type of infrastructure is termed cyber-infrastructure which, as the NSF defines it, ‘integrates hardware for computing, data and networks, digitally-enabled sensors, observatories and experimental facilities, and an interoperable suite of software and middleware services and tools’ (NSF 2006, p. 4). Other terms in common usage are ‘e-Research’, or more specifically, ‘e-Science’ or ‘e-Social Science’, which often involve team-based research conducted across institutional and jurisdictional boundaries.
In Australia, significant investment in specific discipline-based repositories in the sciences has occurred, with the Department of Education, Science and Training (DEST) having funded several projects through the Systemic Infrastructure Initiative (SII), including Repositories of Online Digital Objects (FRODO) projects in 2003, and the Managed Environments for Research Repository Infrastructure (MERRI) projects in 2005 (Denison et al 2007). Since 2006, there have been a number of projects to develop more broad-based repositories and Monash University has been involved in several of these: the Australian Research Repositories Online to the World (ARROW – http://arrow.edu.au/), the Dataset Acquisition, Accessibility, and Annotations e-Research Technologies (DART – http://dart.edu.au/), the Australian Research Enabling environment (ARCHER – http://archer.edu.au/); and the Australian National Data Service (ANDS – http://ands.org.au).
Readily-identifiable issues in e-research
The Australian Code for the Responsible Conduct of Research includes several provisions relating to the preservation and accessibility of research data. It recommends that research institutions must have policies ‘that address the ownership of research materials and data, their storage, their retention beyond the end of the project, and appropriate access to them by the research community’ and that while specific questions of ownership and questions of retention are determined by law or the funding agency, where possible ‘the period for which data should be retained should be determined by the specific type of research’. However, where the work has community or heritage value, the aim should be that it be kept permanently, preferably within a national collection and, ‘unless specifically prevented by ethical, privacy or confidentiality considerations, research data should be made available for use by other researchers’ (NHMRC 2007).
Research data must also be maintained in a durable form, must be indexed or catalogued so as to facilitate discovery, must be accompanied by details of research methods and data sources, and must be managed according to legal and ethical requirements, which include details of approvals granted for subsequent use by third party researchers.
The Atkins report notes that e-Research infrastructure should provide an ‘effective and efficient platform for the empowerment of specific communities of researchers to innovate and eventually revolutionize what they do, how they do it, and who participates’ (ACLS 2006 6). These guidelines (or rules) should be associated with permissions relating to management of resources by authorised users, including disposition (that is, the right to delete information, retain for a set time or indefinitely, or transfer ownership), specified or negotiated conditions of use, rights management (including rights of access, confidentiality and privacy, ownership including copyright and moral rights), and information security safeguards, in particular audit trails which capture and maintain information about the movement and use of the resources.
Needless to say, there are a number of issues that need to be addressed if these policies are to be fully realised. Denison et al (2007), investigating researchers’ attitudes to e-Research environments, found that the technical and non-technical issues associated with e-Research were intimately entwined, and had the potential to retard the take-up of the infrastructure. Issues included knowledge about which data to store, data management rights, system requirements, accountability, work preferences, access to IT support, trust in repositories and their host organisation, as well as benefits vs. cost, in terms of money, time and effort.
In this context, data management falls into two broad areas: management of current data for the purposes of undertaking the actual research; and longer-term curation of selected data to meet institutional and funder needs, or to make the data more broadly available, for example, as base data to be used by others, or for verification of the research undertaken.
There are several developments which require further attention to questions of ownership. For example, negotiations between research partners in relation to the ownership of the data produced during a study may need to include a broader range of stakeholders, such as the subjects of research whose rights might not have been previously considered under previous protocols. Another development is the increasing use of collaborative tools such as wikis and annotation software, which may involve the shared creation of data or other research outputs, and in which the question of the ownership of those outputs becomes quite obscure. The problem is that if researchers believe that they are going to lose recognition for their work, or ownership of intellectual property, they may withhold material, or refuse to contribute. Such behaviour weakens the potential usefulness of tools for collaboration, but it can be minimised if an appropriate framework is in place which results in trust in the system. In a situation where there is an established culture and a range of precedents to rely upon, it may be possible to create a trusted relationship on the basis of informal understandings. At the present stage of development of e-Research infrastructure and collaborative tools, neither the culture nor the precedents exist.
There is also a need to build collaborative virtual environments for geographically distributed researchers, whether they be members of a lead institution or external to that institution, or whether they be community-based researchers or interested stakeholders. Collaborative systems, for example those based on the Sakai or Confluence packages, have recently been implemented at Monash, however their prime purpose is to provide access to data storage facilities, and their interfaces are decidedly user-unfriendly (Denison et al 2007).
Previous research has found a lack of clarity about data ownership (Denison et al 2007, Henty et al 2008), which may have repercussions when assessing what access rights can be assigned to data and at what stage. These problems are very real in terms of e-Research practice. If there is no clarity about barriers to depositing datasets, then researchers may choose not to deposit at all, or may choose to place tighter restrictions on the data than is actually necessary. At the very least, repositories will need to include metadata that describes a range of options relating to ownership, and the specific rights of users in relation to the data held.
Henty et al (2008) surveyed researchers at three Australian universities and found that over 60% of researchers were willing to make their data available at some time, although 44% responded that they would require a ‘negotiated access’, and only 8.6% were willing to allow open access. They also reported that only 0.8% had already provided access through a formal data archive such as the Australian Social Science Data Archive or IATSIS.
Just as there is no clear understanding of who owns data produced as part of the research process, there is also a lack of awareness of data management and archiving policies and procedures in force within researchers’ organisations. Denison et al (2007) found evidence that long-term data management and archiving was falling between gaps in perceived responsibilities.
As noted above, if researchers are to be able to re-use data, they must be able to find data via some standard search and discovery mechanism, understand the provenance of the data and its meaning, and have a clear understanding of the ways in which it is permissible to use the data. Anderson and Carlson (2006) drew particular attention to the difficulty of preserving the meaning of data once it has been detached from its source. Henty et al (2008) found that many researchers considered their data would be meaningless to others because they would not have sufficient context to interpret it. Different types or levels of metadata are required depending on the roles of those involved. While those creating or depositing the data need to add metadata related to provenance and meaning, those in charge of curating such data need to know enough about it to decide how long the data should be kept for, and what its value is. For example, at the basic storage level when data is being generated, decisions would have to be made about how often snapshots of the data should be backed up and/or archived.
Another issue is control, or at least perceived control, over data storage and access. Relevant factors include the level of personal control maintained over data and workflows, trust in data management systems and security arrangements, and time management on the part of the researcher, whether that be to manage data or to investigate and adopt new systems and procedures. Information security is essential to the development of trust in this environment; establishing an appropriate legal framework is a crucial concern. An inability to adequately address such non-technical issues leads to ‘researchers continuing with their manual data management practices, despite the risks, in particular data loss, and the additional work involved’ (Denison et al 2007).
Participatory research and empowerment
Research relationships and questions of data ownership can be more complex in social science research than in other disciplines, particularly when the research engages with communities. According to Stoecker (2005) new models of participatory community research require a number of features, including acknowledging communities as equal partners, basing the research on problems important to the community, and the research and its outputs are owned by all participants. In such scenarios, community members may have quite different functions from those in the past, and sit somewhere along the spectrum of: researcher, subject-researcher, consumer-researcher, stakeholder-researcher, and partner-collaborator.
Community-based research relies upon mutual understanding and articulation of researcher and community values which, on both sides, may have been thought of before only as part of a tacit understanding between each community’s members, when functioning within their own familiar contexts (Johanson et al 2007). A departure from the more traditional approach can be observed in community-based research. In the traditional role of research, communities and community members tend to be thought of as the subjects of the research, rather than as participants. In the new form of practice, common understanding is a starting-point. The aims, expectations, methodologies, outcomes and other stages of the research, can only be developed when trust has been established and the interests of all stakeholders have been well aired through a common language (Stoecker 2005).
Clearly, then, community-based research is situated or ‘embedded’ research that has to be based on mutual trust and respect, which can only be achieved if concomitant ethics regimes are based on principles and guidelines that are adapted to meet community concerns.
Such issues find coherent and comprehensive expression in the AIATSIS (Australian Institute of Aboriginal and Torres Strait Islander Studies) protocols, developed for conducting research in partnership with indigenous communities, as follows:
A.Consultation, negotiation and mutual understanding
1.Consultation, negotiation and free and informed consent are the foundations for research with or about Indigenous peoples.
2.The responsibility for consultation and negotiation is ongoing.
3.Consultation and negotiation should achieve mutual understanding about the proposed research.
B.Respect, recognition and involvement
4.Indigenous knowledge systems and processes must be respected.
5.There must be recognition of the diversity and uniqueness of peoples as well as of individuals.
6.The intellectual and cultural property rights of Indigenous peoples must be respected and preserved.
7.Indigenous researchers, individuals and communities should be involved in research as collaborators.
C.Benefits, outcomes and agreement
8.The use of, and access to, research results should be agreed.
9.A researched community should benefit from, and not be disadvantaged by, the research project.
10.The negotiation of outcomes should include results specific to the needs of the researched community.
11.Negotiation should result in a formal agreement for the conduct of a research project, based on good faith and free and informed consent.
The AIATSIS Guidelines pay particular attention to the issues of ownership and presentation of results. They state that researchers must recognise that ‘the knowledge and resources Indigenous peoples bring to the project remains their intellectual property’, and further: ‘the rights to, the forms and presentation of, individual or community use of, and access to, research results should be agreed’. These provisions have implications for the ownership of research results, institutional ownership of data, the individual rights of researchers and Indigenous participants to the data, and the collective rights of Indigenous community groups. They extend to questions of community control over access to, and use of, research results, and on the disposition and storage of data and other outputs.
Although the above principles are specifically targeted at work with indigenous communities, the same ethical approach could apply to working with non-indigenous communities when dealing with culturally sensitive or other materials (e.g. Holocaust survivor’s personal records).
Communications networks have the potential to liberate the content and manner of research from old structures however two significant shifts in approach are required. First, the community will have to be able to fully interact with the information and community technologies in place, and to have meaningful input into their design and deployment. Second, as Stoecker (2005) notes, although the research community is empowered to create, collate, disseminate and control its own products, and so to effect change, it will only occur if it conforms to an overall community development strategy (Stoecker 2005 34). Shared information with multiple contributors and owners does not fit neatly into existing personal property law (Iacovino 2006).
Russell (2005) used the term ‘irreconcilable ontologies’ to reflect differences between Western and Indigenous Australian knowledge systems due to them being based on different world paradigms. As Faulkhead et al comment ‘attempting to match these two systems of knowing often results in one system being subsumed by the other, or one being presented as an alternative to the other; not in them being equal but different worldviews’ (2007: 41). The ontological problem affects academic ethics processes, which are based on Western concepts of privacy, informed consent, and the ownership and control of data by academics, and which focus on protecting the interests of the university rather than those of any community. Faulkhead et al go on to note that:
although it is possible to vary the standard approaches to managing relationships with community partners and handling research data, the standard approaches reveal a lack of sensitivity to community protocols, with it being possible for community projects to gain ethics approval without adequate community consultation, or full compliance with community protocols (Faulkhead et al 2007: 50).
The typical role of communities in the Western research paradigm is to treat them as research subjects rather than partners in research.
Legault and VanderPlaat discuss similar issues surrounding NGO-University partnerships. In particular they note that different organisational cultures raise many challenges about ways of ‘working, thinking, organizing and communicating’ (2007: 197), and that the modus operandi challenge power imbalances in the collaborative process, and the nature and purpose of research.
The Participatory Community e-Research project
This project was designed to explore governance frameworks which can be applied in new e-Community contexts, and to identify the user needs of e-Researchers, funding providers, their collaborators, industry partners, community partners, and e-Research consumers. It stresses the importance of facilitating participation, by addressing issues which arise from the new management principles required for the authenticity, accessibility, disposition and preservation of electronic resources for multiple purposes, and more abstract issues, such as trust. The findings are based on data collected during the Participatory Community e-Research project conducted by the Centre for Community Networking Research (CCNR) at Monash University between 2008 and 2009. During July-August 2009 12 in-depth interviews were undertaken with non-science researchers, and an online survey into data management practices was administered, attracting 67 usable responses.
The project also draws on experience gained during two other recent projects. The first, ‘Trust and Technology: building an archival system for Indigenous oral memory’, an Australian Research Council Linkage project, dealt with oral memory as captured within narratives that constitute Koorie knowledge and contrasted them with the dominant mainstream narratives deposited in government and institutional archives (Faulkhead et al 2007). The second was undertaken in 2008 by staff of the Centre for Organisational and Social Informatics (COSI) at Monash University, as part of the Dataset Acquisition, Accessibility, and Annotations e-Research Technologies (DART – http://dart.edu.au/) project.
As noted, the study was conducted in two parts -- a survey and a series of twelve semi-structured interviews. The survey was designed to quantify the occurrence of high-level practices relating to the use of research data repositories and data management practices. 67 usable responses were received from a wide range of researchers, including not only those engaged in the social sciences and the arts, but also those engaged in business, management and economics research.
The findings of most relevance to this paper are those relating to the 69% of researchers who reported that they create or collect original data (most others purchased pre-existing datasets for example, those working in econometrics). Of those who worked with original data
-54% of respondents stated that their data was subject to a University mandated disposal period, either five or seven years after the completion of the project, depending on the discipline,
-only 30% made use of centrally-managed data storage facilities provided by the University, with the remainder storing their data on their own PC,
-21% said that they would not use centralised data storage facilities because they did not trust either the management of those facilities or their security, and
-85% reported only ever backing-up their data to CD-ROM or USB sticks.
These finding are in line with previous studies and suggest a worrying ignorance of good data management practices.
Of more interest to this paper were the semi-structured interviews, which focused on researchers primarily engaged in research involving people or communities. The semi-structured interviews were conducted to identify and explore issues relating to data collection, data management, and the ethical, legal and institutional frameworks within which researchers operated. The themes explored included:
-The nature of their collaboration with local or cross-institutional research teams, and any others who might be regarded as partners or stakeholders in the research.
-Ownership of data, particularly that involving human participants.
-The data in its relationship to the outcomes or products of research.
-Management of data storage, backup and archiving.
-Software used in capturing, manipulating or publishing data.
-Software used to support collaboration.
-The nature of the information kept about the data files collected.
-The expected life-time of value associated with data collected. Attitudes to making original data available to other researchers and the problems involved -- legal, contractual, ethical, and logistical.
-The conditions under which re-use would be permitted.
-Interviewees’ own re-use of third party datasets and conditions on that use.
-Use of data repositories, including those external to the university.
Because of space constraints, it is not possible to present the complete findings here. Rather, the focus will be on those findings most relevant to the theme of participatory e-Research. These can be grouped under six headings: lack of awareness of available institutional systems; resistance to institutional system limits; data management and data security; data ownership; dataset re-use; and ethics frameworks.
1. Lack of awareness of available institutional systems.
2. Resistance to institutional systems limits.
There was a significant trend to avoid centralised services because they were perceived as not very user-friendly, they could not meet requirements or, in some cases, there were doubts about the efficient management of the service. For example, many reported having access only to a shared network drive with limited storage capacity, or which could not be accessed by partners and collaborators external to Monash. Researchers reported having little hesitation in avoiding the use of institutional systems when those systems were perceived as being subject to unnecessary constraints or as being difficult to use. For example, many researchers had problems with use of the Monash email system, which has a 2 megabyte limit on the size of attachments, and an overall storage capacity of 300 megabytes. The aim of the limits is to discourage the use of the email system for exchanging (and storing) large data files, and so to act as an indirect means of encouraging staff to use shared data storage facilities and collaborative tools. A significant number of the researchers interviewed, supported by numerous comments made in the online survey, indicate high levels of frustration with the limits. In fact the limit was counterproductive, rarely resulting in researchers using the available shared facilities. Mostly, it resulted in the use of services such as Google Docs and Gmail, an ironical result, because although many reported that trust in the system to preserve the confidentiality of the data was important, many also chose to use a freely available and user-friendly services rather than the supposedly more secure university facilities.
3. Data management practices / data security
Most researchers interviewed had a strong tendency to want personal control over their research data, which generally meant that they kept their data on their personal computer with back-ups typically kept on USB sticks, or in some cases CD-ROMs or DVDs. This provided a sense of having more immediate access to other data as well as more control over who could access it. Although these are important considerations, these practices are usually accompanied by the risk of losing data through having poorly managed back-ups, a lack of version control, and a lack of planning regarding the post-project life of the data in question. These practices are in part connected to the first two issues, that is a lack of awareness of what institutional systems are available and dissatisfaction with the constraints that they impose, but in many cases the sense of security and control provided by current practice is illusory.
4. Data ownership
There appears to be a growing trend to publish datasets, and in some disciplines a need for perpetual access, however many researchers commented on a variety of problems. Prominent among these were conflicting attitudes to ownership of data. For example, the ownership of data collected during interviews involves issues such as copyright in the questions used, the rights of indigenous communities; and notions of assigned copyright.
Those involved in participatory research argued that any data collected needed to be regarded as the joint property of the participants and the researchers, with the knowledge and opinions expressed clearly acknowledged as those of the participants. However in most cases the University and ethics documents require that the researchers, or the University, be specified as the owners, and that the participants' knowledge be considered in terms of pre-existing intellectual property. This may not appear a significant difference in attitudes, however the consequences are that it is the University that controls what can be done with the data, who has access to it, and when it must be disposed of. Those involved in oral history, especially those working from the more traditional perspective of regarding those being interviewed as the subject of the research, were comfortable with the idea that copyright remained with the researcher. However even in those cases case-by-case negotiation was necessary and provided a major source of frustration.
5. Dataset re-use.
Attitudes to the future use of data varied and were the subject of uncertainty, with researchers wanting to facilitate access as far as possible, but needing to reconcile such access with ethical and procedural concerns, such as acknowledgement of their collection of the original data, having to place individual requests with the original participants, and the need to insure that the data was being used in an ethical manner and in full compliance with legal and other issues.
Many interviewees commented that the data as stored would not be useful to other researchers because it would lack sufficient context for interpretation. Some added that the problem could be overcome but that to do so would require significant intellectual effort in preparing appropriate metadata and 'clean' data sets – which they implied was outside of their normal tasks. The exceptions were those who thought their work had perpetual value, such as oral historians or those researching threatened languages and cultures. Typically such researchers planned for the deposit into repositories and long-term access from the start of the project. Some only came to such objectives once they were well into their research, and this had the potential to cause problems. For example, in one project a change of staff combined with a lack of contextual metadata resulted in six months worth of interviews being rendered almost useless, so much so that new interviews had to be conducted.
Most researchers reported that, because of the default position adopted by the University ethics framework, their data was to be destroyed either 5 or 7 years (depending on the discipline) after the completion of their project. Most accepted that without question, including a number who thought that their data might have more lasting value.
6. Ethics frameworks
Perhaps the most important issue from a Community Informatics perspective related to the difficulties encountered in reconciling the University's ethics framework with the needs and rights of external partners in the research undertaken. This was not reported as a problem by those working within a more traditional research environment which tends to regard people and communities as subjects of the research and the ownership of any research outputs as being that of the researchers. However, those that considered external participants as partners who might own or share ownership of the data and research outputs found it more difficult, but not impossible, to work within the current ethics framework, and that the constraints of that framework were a major source of frustration. The issue of data ownership has been mentioned above. Other common complaints were that the framework was overly complicated, did not take into account the needs and rights of partner communities, and was overly-cautious in that it assumed that re-use would not be permitted and would have to be argued on a case-by-case basis.
Overall, those researchers involved in some form of community-based research in which they regarded the community as being participants rather than the subject of the research, reported that although the Monash ethics framework was gradually improving and becoming more flexible in terms of the range of arrangements permitted, ethics clearance for that type of research still had not been accepted as standard and required significant negotiation on a case-by-case basis.
While it is clear that the physical location of electronic resources is of decreasing importance, control and ownership, as reflected in intellectual property policies and ethical requirements, have become highly contested. The current research has confirmed recent research findings which suggest that problems relating to trust and usability of institutional repositories will impede their take-up by researchers. It also suggests that such problems will be particularly acute in relation to new models of participatory research involving communities.
In terms of e-Research, at least at Monash, issues related to the management of repositories and the re-use of data appear to be gradually being resolved, but at the moment are still being resolved on a case-by-case basis and so need more standard protocols on re-use which recognise the broader range of ownership and copyright possibilities. The Australian Code for the Responsible Conduct of Research states that where research has community or heritage value, the aim should be that it be kept permanently, and, ‘unless specifically prevented by ethical, privacy or confidentiality considerations, research data should be made available for use by other researchers’ (NHMRC 2007: 2.3). An examination of current data management practices suggests that much still needs to be done to achieve this aim.
With respect to data preservation, clear ownership of information resources in e-Research communities, including ownership of intellectual property is critical for accountability, long-term storage, accessibility and archiving. The resolution of the ownership of intellectual property is particularly complex in universities and other research institutions which adopt principles in intellectual property policies which alter the way in which legislation vests ownership. Within the social sciences and the humanities, particularly when dealing with communities and individuals in ethnographic work, there may be broader questions about who actually owns the research – the researcher, the community, the group? – as well as exactly what it is that comprises the research content, and what can be done with it. Such questions need negotiation, and that negotiation can be more complex than what existing frameworks currently provide for. It is clear that such guidelines as do exist, for example the AIATSIS protocols for conducting research with indigenous communities, are not well served by current arrangements.
That framework should include:
1)Allowance for joint ownership / a select number of non-standard possibilities,
2)More flexible rules regarding retention of data,
3)Greater recognition of specific community ethics frameworks,
4)Recognition of prior ownership of knowledge,
5)Protocols for re-use, and
6)Recognition of authorised repositories and criteria for the accreditation of new ones.
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