Data Matching Program with AFSA


1 Overview

The Guidelines for Data-matching in Commonwealth Administration, issued by the Office of the Federal Privacy Commissioner, specify that a program protocol be prepared by agencies undertaking certain data-matching programs. These guidelines are voluntary and are not legally binding. The Australian Securities and Investments Commission ("ASIC") has agreed to comply with the guidelines.

ASIC is an independent Commonwealth government body established by the Australian Securities and Investments Commission Act 1989 and continued in existence by the Australian Securities and Investments Commission Act 2001 ("the ASIC Act"). ASIC enforces company and financial services laws to protect consumers, investors and creditors. In performing its functions and exercising its powers ASIC is enjoined to strive, among other things, to:

  • maintain, facilitate and improve the performance of the financial system and the entities within that system in the interests of commercial certainty, reducing business costs, and the efficiency and development of the economy;
  • promote the confident and informed participation of investors and consumers in the financial system;
  • ensure that information is available as soon as practicable for access by the public; and
  • take whatever action it can take, and is necessary, in order to enforce and give effect to the laws of the Commonwealth that confer functions and powers on it. (See subsection 1(2) of the ASIC Act.)

ASIC maintains Australia's public database called "ASCOT" that contains information on over 1.3 million Australian companies (see sections 1274, 1274AA and 1274A of the Corporations Act 2001 and the Corporations Regulations 2001 (the Regulations)). ASCOT contains the details of company officeholders, including directors and secretaries.

The Australian Financial Services Authority ("AFSA") is an Executive Agency in the Commonwealth Attorney-General's portfolio and is responsible for the administration and regulation of the personal insolvency system in Australia. AFSA also maintains the public records on personal insolvency on a publicly accessible register of all bankruptcies and personal insolvencies in Australia known as the National Personal Insolvency Index ("NPII") (see the Bankruptcy Act 1966 and the Bankruptcy Regulations 1996).

A person;

  • who is an undischarged bankrupt; or
  • who, prior to 1 December 2004, has executed a deed of arrangement under Part X of the Bankruptcy Act 1966 ("Part X") where the terms have not been fully complied with; or
  • whose creditors, prior to 1 December 2004, have accepted a composition under Part X where final payment has not been made under the composition; or
  • has, on or after 1 December 2004, executed a personal insolvency agreement under Part X of the Bankruptcy Act 1966 or a similar law of an external Territory or a foreign country and the terms of the agreement have not been fully complied with;

is automatically disqualified from managing corporations by operation of subsections 206B(3) and (4) of the Corporations Act. Such a person ceases to be a director, alternate director or a secretary of a company unless they are given leave by the Court to manage corporations in accordance with section 206G of the Corporations Act. Such persons who continue to manage corporations without the leave of the Court are guilty of an offence under the Corporations Act (section 206A of the Corporations Act).

In accordance with subsection 205B(5) of the Corporations Act if a person ceases being a director, alternate director or secretary of the company, the company has an obligation to lodge with ASIC a notice of the fact within 28 days. It is an offence to fail to notify ASIC.

ASIC and AFSA entered into a Memorandum of Understanding on 22 April 2002. The Memorandum of Understanding was entered into in recognition that cooperation between them is desirable bearing in mind ASIC's responsibilities for the regulation of corporate insolvencies and AFSA's role as regulator of personal bankruptcies.  

2 Objectives

The results of this data-matching program between the ASIC public database ASCOT and the AFSA public database NPII will be used by ASIC:

  1. to identify persons who are recorded on ASCOT as being current officeholders of companies but who are:
    • an undischarged bankrupt; or
    • who, prior to 1 December 2004, has executed a deed of arrangement under Part X where the terms have not been fully complied with; or
    • whose creditors, prior to 1 December 2004, have accepted a composition under Part X where final payment has not been made under the composition; or
    • has, on or after 1 December 2004, executed a personal insolvency agreement under Part X or a similar law of an external Territory or a foreign country and the terms of the agreement have not been fully complied with;
  2. to update ASCOT where appropriate; and
  3. to investigate possible breaches of the law.

AFSA will not have access to the results of the data-matching program.

3 Agencies involved

ASIC is the matching agency. The data-matching program will be run on ASIC computer facilities. Approximately 4.1 million current officeholder records on the ASCOT public database will be matched with approximately 300,000 NPII public records.

AFSA will contribute data relating to:

  • undischarged bankrupts;
  • persons who, prior to 1 December 2004, have executed a deed of arrangement under Part X where the terms have not been fully complied with;
  • persons whose creditors, prior to 1 December 2004, have accepted a composition under Part X and where final payment has not been made under the composition; and
  • persons who, on or after 1 December 2004, have executed a personal insolvency agreement under Part X or a similar law of an external Territory or a foreign country where the terms of the agreement have not been fully complied with.


ASIC and AFSA will be the source agencies. ASIC data derived from ASCOT includes:

  • ASIC person number (which is used internally to enable accurate cross-referencing of information);
  • company officeholder's name;
  • company officeholder's date of birth; and
  • company officeholder's address.


AFSA data derived from the NPII includes:

  • name of person who:
    • is an undischarged bankrupt; or
    • prior to 1 December 2004, has executed a deed of arrangement under Part X where the terms have not been fully complied with; or
    • whose creditors, prior to 1 December 2004, has accepted a composition under Part X and final payment has not been made under the composition; or
    • who, on or after 1 December 2004, has executed a personal insolvency agreement under Part X or a similar law of an external Territory or a foreign country where the terms of the agreement have not been fully complied with;
  • person's date of birth;
  • person's address;
  • in the case of bankruptcy, date of commencement and, if applicable, discharge; and
  • in the case of a personal insolvency agreement under Part X or a similar law of an external Territory or a foreign country or a deed of arrangement or composition under Part X, date upon which all of the relevant obligations have been met, if any.

4 Data issues

Data quality: Under subsection 205B(5) of the Corporations Act a company must, within 28 days of a person ceasing to hold office as a director or secretary of the company, notify ASIC. This includes cessation because a person has become automatically disqualified from managing a corporation due to:

  • bankruptcy; or
  • prior to 1 December 2004, executing a deed of arrangement under Part X where the terms have not been fully complied with; or
  • prior to 1 December 2004, the person's creditors accepting a composition under Part X and final payment has not been made; or
  • on or after 1 December 2004, executing a personal insolvency agreement under Part X or a similar law of an external Territory or a foreign country where the terms of the agreement have not been fully complied with.

A person can also directly notify ASIC that they have ceased to hold office as a director or secretary of a company.

Data integrity: Measures taken to maintain integrity levels include designing systems that will not accept incomplete records, and identifying and correcting records with inadequate or corrupt data. Prior to data-matching the NPII records will be screened to ensure that they contain reliable, accurate and timely information. This will involve applying business rules that specify the minimum data requirements an NPII record must satisfy to pass as a valid record for matching against ASCOT data. The business rules are set out in Appendix A. NPII records that do not match the specified minimum data requirements will be deleted and not used in the data-matching process.

Matching reports will then be generated using the screened NPII records to identify persons who are recorded on ASCOT as being current officeholders and whose name and date of birth data have an exact match with NPII data. All matching reports will be manually verified for data quality assurance. This includes comparing ASCOT and NPII address information for each person identified in the matching reports. A person will be deemed to be a "match" for possible administrative action by ASIC where the ASCOT and NPII data match on name(s), date of birth and address. Where any of these data elements are missing, incomplete or inconsistent it is deemed that these persons cannot be matched and no further action will be taken.

Data Security: ASIC staff are subject to the confidentiality provisions of the ASIC Act, the ASIC Code of Conduct and ASIC information management policies. Access to ASCOT data is currently strictly controlled and entry properly authorised. Features include logon identification codes, passwords and security groupings to ensure that access to information is on a "need to know" basis only. Existing security arrangements in ASIC automatically log user access to data files.

Each cycle in the matching program will produce statistics on the number of records matched and unmatched. When each matching report is actioned, ASIC will maintain a record of the logon identification code of the actioning officer, the action that was taken in respect of the matched report and when the action was taken.

Where ASIC receives information from AFSA in accordance with this program protocol, it will take all reasonable steps to ensure that such information is only used for the purpose for which it was obtained.

5 The matching process

On a weekly basis ASIC will download from AFSA an NPII update file using a secure web interface that is password protected at each level. The file includes the details of:

  • new bankrupt persons;
  • those who, prior to 1 December 2004,
    • executed a deed of arrangement under Part X where the terms have not been fully complied with; or
    • who have accepted a composition under Part X where final payment has not been made under the composition;
  • those who, on or after 1 December 2004, have executed a personal insolvency agreement under Part X or a similar law of an external Territory or a foreign country where the terms of the agreement have not been fully complied with; and
  • updates with respect to existing bankruptcies, personal insolvency agreements and deeds of arrangement or compositions under Part X.

Downloaded NPII records will then be screened prior to an automated matching report being generated each week. This will involve applying business rules that specify the minimum data requirements an NPII record must satisfy to pass as a valid record for matching against ASCOT data. (See the business rules set out in Appendix A.) NPII records that do not match the specified minimum data requirements will be rejected.

The matching reports will identify those persons who are recorded on ASCOT as being current officeholders and whose ASCOT data matches the NPII data with respect to:

  • surname;
  • first given name;
  • other given names (if any); and
  • date of birth.

All matching reports will be manually verified for data quality assurance. This includes staff comparing ASCOT and NPII address information for each person identified in the matching reports. Where an address match between ASCOT and ITSA data is confirmed in respect of a particular person, that person will be deemed to be a "match" for possible administrative action by ASIC.

Where it is not possible to confirm an address match the record relating to the person concerned will be rejected and the information destroyed as soon as practicable after the relevant matching process has been completed. This will occur no later than 90 days after the matching report was generated. No further action will be taken against the person concerned.

Further verification will take place with regard to the persons deemed to be a "match" for possible administrative action by ASIC. This is to see if any of the relevant data has been updated since the generation of the relevant matching report. An additional report will be generated from existing ASIC data to identify the last notified address held by ASIC in respect of each matched person, and all current company roles held by them, as recorded on ASCOT. Any inconsistent address information will be manually verified prior to any administrative action being taken. Any administrative action by ASIC will be taken no later than 90 days after the matching process has been completed.

6 Action resulting from the program

(1) All matched persons selected for possible administrative action by ASIC will be sent an initial notice. This first notice is set out in Appendix B. It will be sent to their last notified address held by ASIC as recorded on ASCOT. It will advise the person of the match and that they may be disqualified from managing a corporation. A Form 296 Notification of disqualification from managing a corporation (Form 296) will be included with the notice. The Form 296 is set out in Appendix C.

The notice shall provide the person concerned with an opportunity to notify ASIC within 28 days of their current status by either:

  1. lodging confirmation of the disqualification using the enclosed Form 296; or
  2. providing written information to satisfy ASIC that the person is not bankrupt or otherwise disqualified.

The person concerned, therefore, has an opportunity to respond to the information about the match before any action is taken by ASIC.

(2) Where a person completes the Form 296 and lodges it with ASIC within the 28 day period specified, ASIC will update ASCOT to reflect the information provided therein.

(3) Where written correspondence is received from the person refuting that they are bankrupt or otherwise disqualified, ASIC may investigate the matter further. Documentary evidence may be requested from the person during this process. What, if any, further action may be taken as a result of ASIC's investigation will in turn depend on the facts of each matter.

(4) Where the person concerned does not respond to the notice within 28 days or the notice is "returned to sender", a second notice will be sent to the registered office of each company of which the person is recorded on ASCOT as being a current officeholder. This second notice is set out in Appendix D. It will inform each company of the match and that the person so recorded may be disqualified from managing a corporation.

The notice shall provide the company with an opportunity to notify ASIC within 21 days of the current status of the person concerned by either:

  1. lodging confirmation of the cessation of the officeholder using a Form 484 Change to company details (Form 484);or
  2. providing written information to satisfy ASIC that the person is not disqualified.

The company, therefore, has an opportunity to respond to the information about the match before any action is taken by ASIC.

(5) Where the company completes a Form 484 and lodges it with ASIC within the 21 day period specified, ASIC will update ASCOT to reflect the information provided therein.

(6) Where written correspondence is received from the company or person concerned refuting that the person is disqualified, ASIC may investigate the matter further. Documentary evidence may be requested from the company or person during this process. What, if any, further action may be taken as a result of ASIC's investigation will in turn depend on the facts of each matter.

(7) Where the company does not respond to the second notice within 21 days or the notice is "returned to sender" a third notice will be sent to the principal place of business of each company of which the person is recorded on ASCOT as being a current officeholder. This third notice is set out in Appendix E. It shall advise the company that as no response has been received ASIC intends to update ASCOT within 14 days to show that the person concerned has ceased to be an officeholder of the company. The company, therefore, has another opportunity to respond to the information about the match before any action is taken by ASIC.

(8) Where the company completes a Form 484 and lodges it with ASIC within the 14 day period specified, ASIC will update ASCOT to reflect the information provided therein.

(9) Where written correspondence is received from the company or person concerned refuting that the person is disqualified, ASIC may investigate the matter further. Documentary evidence may be requested from the company or person during this process. What, if any, further action may be taken as a result of ASIC's investigation will in turn depend on the facts of each matter.

(10) Where the company does not respond to the third notice within 14 days or the notice is "returned to sender", ASIC will update ASCOT to show that the person concerned ceased to be an officeholder of the company. A final notice will then be sent to each company of which the person was an officeholder to advise that ASIC has taken such action. This final notice is set out in Appendix F.

7 Time limits applying to the conduct of the program

Data will be destroyed in accordance with the Office of the Federal Privacy Commissioner's guidelines on The Use of Data-matching in Commonwealth Administration.

Each week a matching report will be generated from the NPII download. NPII data deemed unsuitable for data-matching will be not used in the matching process and will be destroyed as soon as practicable after the relevant matching process has been completed. This will occur no later than 90 days after the matching report was generated. Matched NPII data stored and used as part of the matching process will also be manually destroyed within 90 days of being generated.

8 Public notice of the program

A notice announcing the commencement of the matching program was published in the Commonwealth of Australia Government Gazette No. B 8A on 24 February 2004.

9 Relationship with the agencies’ lawful functions and activities
The program is directly related to ASIC's statutory obligations with respect to the maintenance of public registers and to ensure the integrity of the information on those registers (see Part 9.1 of the Corporations Act, the Regulations and subsection 1(2) of the ASIC Act).

Further, the Royal Commission into the Building and Construction Industry ("the Cole Royal Commission") considered the issue of, and made a number of recommendations with respect to, bankrupt persons acting as directors of companies in the building and construction industry. The program is consistent with the recommendations made by the Cole Royal Commission in this regard.

10 Legal authority

As noted above, ASIC is enjoined to enforce and give effect to the laws of the Commonwealth that confer functions and powers on it (subsection 1(2) of the ASIC Act).

ASIC, through the program, aims to ensure compliance with the legal requirement that a company notify ASIC of the cessation of its officeholders (see subsection 205B(5) of the Corporations Act). Further, as noted above, a person;

  • who is an undischarged bankrupt; or
  • who, prior to 1 December 2004, has executed a deed of arrangement under Part X where the terms have not been fully complied with; or
  • whose creditors, prior to 1 December 2004, have accepted a composition under Part X where final payment has not been made under the composition; or
  • has, on or after 1 December 2004, executed a personal insolvency agreement under Part X or a similar law of an external Territory or a foreign country and the terms of the agreement have not been fully complied with;

is automatically disqualified from managing corporations by operation of subsections 206B(3) and (4) of the Corporations Act. Such persons cease to be a director, alternate director or a secretary of a company unless they are given leave by the Court to manage corporations in accordance with section 206G of the Corporations Act. Such persons who continue to manage corporations without the leave of the Court are guilty of an offence under the Corporations Act (see section 206A of the Corporations Act).

ASIC also aims to ensure compliance with such laws by reminding the purported officeholders and companies concerned that it is an offence for persons who are bankrupt or otherwise disqualified to manage a corporation. ASIC may also take further action where appropriate.

ASIC has a further objective of updating ASCOT information on company officeholders where appropriate. ASCOT is a register that ASIC maintains in accordance with section 1274 of the Corporations Act. ASIC is enjoined to ensure that information is available as soon as practicable for access by the public (subsection 1(2) of the ASIC Act).

The use and disclosure of information in these circumstances are authorised by law and may be reasonably necessary for the enforcement of the criminal law or a law imposing a pecuniary penalty. Information Privacy Principles 10(c) and 11(d) in section 14 of the Privacy Act 1988 clearly apply. To the extent law enforcement is involved, Information Privacy Principles 10(d) and 11(e) may also apply.

11 Alternative method

There is no alternative single source of information available in relation to the connection between persons who are recorded on ASCOT as being current officeholders and those persons who are bankrupt or otherwise disqualified from managing corporations.

12 Costs and benefits

A project has been established to develop and implement this program for ASIC.

The establishment costs are largely comprised of staff costs associated with the development of systems and processes to manage the program. The total cost of the project is low with staff opportunity costs estimated to be less than $50,000. No cash expenditure is required on goods and services.

Costs associated with conducting weekly runs of the program and with following up data matches are expected to be minimal as the potential number of matches is estimated to be approximately 8-10 per week.

It is expected that there will be an improvement in voluntary compliance by companies with statutory obligations to notify ASIC of changes in circumstances of officeholders. This will be due to the increased likelihood that ASIC will be able to detect whether a person recorded on ASCOT as being a current officeholder has been automatically disqualified from managing a corporation.

It is also expected that the maintenance of the ASIC public registers will be improved, as the information they contain about officeholders will become more up-to-date through improved notification of changes and the verification of such information through the data-matching process. Better data quality and integrity for the public may enhance the confident and informed participation of investors and consumers in the financial system. Improvements in ASIC's administration and control of the processing of bankruptcy and Part X notifications is also expected.

ASIC plans to conduct a review of the program once implemented to assess the effectiveness and efficiency of the program as well quantify the expected benefits and costs.

Appendix A: Business rules

These business rules specify the minimum data requirements an NPII record must satisfy to pass as a valid record for the purposes of the data-matching program:

NPII Data Item Field Value
Surname Must be populated
First given name Must be populated
Other given name/s May be blank
Date of birth Must be populated
Address Must be populated. Minimum of Town and State
Date started Must be populated. Must be less than 2 years and 10 months from download date
Date ended Must be blank
Date deceased Must be blank
Date Statement of affairs filed If populated must be less than 2 years and 10 months old from the download date
Bankrupt type Must be either Sequestration, Composition, Arrangement, Debtor's Petition or Personal Insolvency Agreement
Petitioning Creditor result Must be either 'Null', 'Composition', 'Arrangement' or 'Personal Insolvency Agreement'

Appendix B: First notice

Dear Sir/Madam

Possible disqualification from managing corporations

The Australian Securities and Investments Commission (ASIC) has received publicly available information from the Australian Financial Security Authority indicating that you may be a person who:

  • is an undischarged bankrupt under the Bankruptcy Act 1966; or
  • a person who has entered into a personal insolvency agreement under Part X of the Bankruptcy Act 1966 or a similar law of an external Territory or a foreign country and the terms of the agreement have not been fully complied with.

Such persons are automatically disqualified from managing corporations under subsection 206B(3) or (4) of the Corporations Act 2001. This includes company officeholders.

To determine if your current status on ASIC's corporate register is correctly recorded, ASIC requires you to respond within 28 days of the date of this letter, in one of the following ways:

  • by providing evidence establishing that you are not a person who is automatically disqualified from managing corporations, or
  • if you are automatically disqualified, by completing and returning the enclosed Form 296 (Notice of disqualification from managing corporations – Bankruptcy or Part X arrangement).

If you need assistance or require more information, please visit our website at www.asic.gov.au, contact ASIC's infoline on 1300 300 630 or make an enquiry at www.asic.gov.au/question.

Yours faithfully


Margaret Boothman
Senior Manager Registry Services
Registry Services & Licensing

Appendix C: Form 296

Appendix D: Second notice

Dear Sir/Madam

Possible disqualification from managing corporations

Company Name
ACN

RE: «First_Given_Name» «Surname»

The Australian Securities and Investments Commission (ASIC) has received publicly available information from the Australian Financial Security Authority indicating that the above-named person may be a person who:

  • is an undischarged bankrupt under the Bankruptcy Act 1966; or
  • a person who has entered into a personal insolvency agreement under Part X of the Bankruptcy Act 1966 or a similar law of an external Territory or a foreign country and the terms of the agreement have not been fully complied with.

Such persons are automatically disqualified from managing corporations under subsection 206B(3) or (4) of the Corporations Act 2001. This includes company officeholders.

To determine if their current status on ASIC's corporate register is correctly recorded, ASIC wrote to the person on «First_Letter_Date» giving that person an opportunity to respond but has received no response.

ASIC now requires your company to respond within 21 days of the date of this letter, in one of the following ways:

  • by providing evidence establishing that the person is not a person who is automatically disqualified from managing corporations, or
  • if the person is automatically disqualified, by completing and returning a Form 484 (Change to company details) advising, in accordance with subsection 205B(5) of the Corporations Act 2001, that the person ceased to be an officeholder of your company. In the case of a single officeholder company, the person will need to complete and return Form 296 (Notice of disqualification from managing corporations – Bankruptcy or Part X arrangement).


If you need assistance or require more information, please visit our website at www.asic.gov.au, contact ASIC's infoline on 1300 300 630 or make an enquiry at www.asic.gov.au/question.

Yours faithfully


Margaret Boothman
Senior Manager Registry Services
Registry Services & Licensing

Appendix E:Third notice

Dear Sir/Madam


Possible disqualification from managing corporations

«Company_Name»
ACN «ACN»

RE: «First_Given_Name» «Surname»

On «Second_Letter_Date» the Australian Securities and Investments Commission (ASIC) wrote to your company at the Registered Office. This letter advised that ASIC has received publicly available information from the Australian Financial Security Authority indicating the above-named person may be a person who:

  • is an undischarged bankrupt under the Bankruptcy Act 1966; or
  • a person who has entered into a personal insolvency agreement under Part X of the Bankruptcy Act 1966 or a similar law of an external Territory or a foreign country and the terms of the agreement have not been fully complied with.

Such persons are automatically disqualified from managing corporations under subsection 206B(3) or (4) of the Corporations Act 2001. This includes company officeholders.

To determine if their current status on ASIC's corporate register is correctly recorded, ASIC further advised that it had written to the person on «First_Letter_Date» giving that person an opportunity to respond to this matter, but had not received a response.

Your company was then asked to respond in one of the following ways:

  • by providing evidence establishing that the above-named person is not a person who is automatically disqualified from managing corporations, or
  • if the person is automatically disqualified, by completing and returning a Form 484 (Change to company details) advising, in accordance with subsection 205B(5) of the Corporations Act 2001, that the person ceased to be an officeholder of your company. In the case of a single officeholder company, the person will need to complete and return a Form 296 (Notice of disqualification from managing corporations – Bankruptcy or Part X arrangement).


ASIC has not yet received a response from your company. If no response is received within 14 days of the date of this letter, ASIC will proceed on the basis that the above-named person is disqualified from managing corporations and will update its corporate register to show that the person has, in accordance with subsection 206A(2) of the Corporations Act 2001, ceased to be an officeholder of your company.

If you need assistance or require more information, please visit our website at www.asic.gov.au, contact ASIC's infoline on 1300 300 630 or make an enquiry at www.asic.gov.au/question.

Yours faithfully


Margaret Boothman
Senior Manager Registry Services
Registry Services & Licensing

Appendix F: Final notice

Dear Sir/Madam

Disqualified person ceased to be an officeholder of your company

«Company_Name»
ACN «ACN»

RE: «First_Given_Name» «Surname»

On «date_we_first_wrote_to_company_about_dis» the Australian Securities and Investments Commission (ASIC) wrote to your company at its Registered Office. This letter advised that ASIC had received publicly available information from the Australian Financial Security Authority indicating that the above-named person, who was at the time recorded on ASIC's corporate register as being a current officeholder of your company, may be a person who is automatically disqualified from managing corporations under subsection 206B(3) or (4) of the Corporations Act 2001.

ASIC further advised that it had written to the person on «First_Letter_Date» giving that person an opportunity to respond to this matter but had received no response.

Your company was then given an opportunity to respond. As no response was received, ASIC sent a reminder on «date_of_second_letter_to_company_about_d» to your principal place of business. ASIC indicated in this letter, that if it received no response within 14 days it would proceed on the basis that the above-named person is disqualified from managing corporations and would update its corporate register.

As ASIC has received no response from your company, it has updated its corporate register to show that the above-named person has, in accordance with subsection 206A(2) of the Corporations Act 2001, ceased to be an officeholder of your company.

If you need assistance or require more information, please visit our website at www.asic.gov.au, contact ASIC's infoline on 1300 300 630 or make an enquiry at www.asic.gov.au/question.

Yours faithfully


Margaret Boothman
Senior Manager Registry Services
Registry Services & Licensing

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Last updated: 15/10/2014 12:00