Have you ever taken a loan out from a bank? If you have then you must know how long and tiring the whole process is. You have to go to the bank fill physical forms in most cases, submit loads of documentation and wait for approval. Based on small details of your full financial history the loan may get approved or rejected. If it gets rejected you feel frustrated over spending so much time. Now there is no argument that there are certain loans that we need to get from banks only as there is no other option.
However, what if you are in need of a smaller loan, which does not necessarily classify in a certain type of loans like auto, mortgage, or even a personal loan of a smaller amount. All you need is a small amount of cash advance, then many of us will feel spending so much time and effort in the bank process is not worth the amount you want to borrow. In such cases, we usually end up borrowing money from friends but I think you all will agree no one likes that.
You may wonder what the alternative is. What if we tell you that you can get the cash advance you need by sitting on your couch and without stepping out of your house? All you need is an internet connection and you are good to go. This option is a payday loan. In the beginning, most payday lenders were available as storefront lenders, but these days almost all the good and licensed payday lenders are available online.
Finding a lender – find an online lender by doing some research. Make sure the lender is licensed to operate in your state. Also, understand the rules and regulations set by the government and take care that the lender you chose follows them.
Amount to borrow – this is called the principal amount as in any other loan. Usually, lenders have a limit set by the government on this amount and also some lenders impose a limit in general, as to how much amount they will lend. This amount can differ, however, in general it can be anywhere from $100 to$2000. The amount you request must be something you can payback to ensure that the loan is approved.
Interest Rate – the rate of interest on payday loans is generally higher as they are a small amount and short-term loans. As far as you pay back on time your finance charges should be as per the agreement. However, if you miss payments the finance charges keep piling on and can spin out of control.
Term – these loans are called short-term loans as usually, the tenure is between two to four weeks. This can again change for different lenders or depending on state rules.
The process of application – you will find the online process of application is similar for most of the lenders, with few fields or requirements being different. The lender asks you to fill identification information and loan requirement and asks for some documentation to be uploaded as proof. This documentation helps them to understand if you are capable of paying back the loan. The online forms will be very easy to understand.
So you see how simple it is. From the comfort of your own home and without excessive documentation you can get a cash advance Ohio within a day and you with this you will be spared the discomfort of asking your friends or family for some small amount of money.


Brittany + Tyler were such a fun couple to photograph! It was so fun to see how playful and loving they were with each other the whole shoot.
I had an amazing time with Allie + Cole in this beautiful spot! Amazing views, a perfect golden hour, and just a little bit of wind made this shoot so so fun.
Theseeee detailsssss. Not only are Jessica + Patrick a total babe couple, but they also did such an amazing job at creating a day that was sentimental, fun, and super cool. From the venue to their favors (matches), this 20s inspired wedding was packed full of thought that obviously came from the heart. Congrats you two, so so honored to have documented your day!
Shooting in the city was something a little different for me because when I think of emotional, romantic photos, I picture the setting being in the wild somewhere but man was I wrong. Rae + Michael were so fun and easy to shoot with it kinda felt like we were all just hanging out but they also brought the heat and passion for their photos. They have such a deep connection that made documenting their love effortless. Can't wait to party it up with these babes in Palm Springs for the wedding next summer!
I love the way these two wear their hearts on their sleeves and are so expressive with their love and emotion towards one another. Their wedding day was full laughs, cries, and deep love. The day itself was gloomy (which I loved because Lisa had previously told me that some of her best days had been when it was raining) but they both completely embraced it and it made for a beautiful setting. Congrats you two, you'll have a wonderful life together!
Angelica + Alex were originally planning a big wedding in Houston, Texas but when hurricane Harvey hit, they had to make a few changes. They were still able to get married but most of their guests and vendors couldn't make it (including me). These two were are so inspiring to me because of how they chose to see the good in such a devastating and scary time. I remember talking to Angelica on the phone and trying to imagine how upset and discouraged I would have been but she was so calm and steady. She was just so ready to marry Alex that everything else came second. For their photos, they wanted to do something a little more adventurous than Houston and flew up to Colorado for this beautiful mountain setting. I love the way these two love each other and bring light to those around them.
Beers, your pup, and your best friend all in the place where you got engaged... what could be better? Seriously loved this shoot and how personal Lisa + Currey made it. Lake Brainard is a place Lisa + Currey frequent for camping and hiking and was the exact place Currey proposed to Lisa. They brought an ice chest of beers and their faithful companion Boon and we basically just hung out, it was great.
Dani + Eoin met by chance (she's from California + he's from Ireland) but there's no question they're meant to be together. From the undeniable connection they have to the crazy amount of love and support they have from their friends and family, it's a sure win kinda love. Their wedding was jam packed with loved ones from near and far and it was a celebration for the books. Congrats you two!
Claudia + James are such a fun, generous, down to earth couple and the kind of people you want in your corner. I'm honored to be their friend but also so excited that they asked me to take their engagement photos! If you live in Colorado, St. Mary's Glacier is a MUST (especially in spring). It's shoots like this that make me forget this is my job.
This day was something straight out of a movie. Hannah and Luca are artists, people that have a love and zest for life like no one else I've ever met, this day was such an amazing representation of that. The small Tuscan town of Cortona has been the setting for their love story and I couldn't think of a more perfect or romantic place. Congratulations Hannah and Luca, your love is magic.
Not only are Carly + Mark a super cute couple but they're also an insanely talented backpack making team.
It's crazy how in such a short amount of time you can start to feel so comfortable with people that you had never known previously.
I can't get over the sweet sweet love these two have for each other. You could just tell they love and respect each other so much.
This styled shoot was so fun and inspiring! Joely from Rooted Florals was the creative mastermind behind the vision for this one.
Krystal and Dan... such a beautiful couple. When we first met and they asked me to document their big day I knew it was gonna be great. Two beach loving surf bums tying the knot in one of the prettiest locations - I was all in!
Not only were these lovers obviously gorgeous, they were also so so sweet. You would never know that Brytny was 8 months pregnant, she rocked heels and a dress in some crisp mountain air (yes, that's snow on the ground).
Matthew + Devan had such a special wedding. It was full of thoughtful details and they were surrounded by the most supportive and loving friends and family.


The Valhalla Project: Animals: Why Heritage Breeds?
While many organizations fret over supposedly shrinking or endangered wildlife species, few focus on another real genetic resource, rare and endangered livestock species. Why should we care? Primarily because these are species and breeds most influenced by human intervention and many have extraordinarily unique characteristics that warrants their preservation.
The American Livestock Breeders Association notes that as agriculture has become increasingly industrialized and based on a corporate model fewer and fewer breeds are accounting for more and more of the base herd. For example, more than 90% of all dairy cattle in the US are Holsteins. No problem unless something hits that breed and it crashes. In the scramble to replace them we could come up short on genetic diversity needed if alternative breeds are extinct.
Typically these breeds - often referred to as Heritage breeds - are multi-tasker animals or fowl. Heritage cattle will give meat, milk, and pulling capacity. Chickens meat and eggs and are good breeders. Goats, meat and milk, and so forth. Animals that perform a multiplicity of functions fit well into Valhalla where everyone works - most often at several jobs! We won't get a break, why should the critters? Ain't fair!
Another great reason for Heritage breeding is that there are grants out there for organizations that focus on expanding the breed lines as well as the fact that they are usually people-friendly, very hardy and disease resistant, make a good living on free range or pasture, and take care of their needs - breeding and raising young - without a lot of human intervention. All good.
Having Heritage breeds tends to spotlight the facility in a positive way and attracts attention for its own sake. If we can leverage some of this attention into support for Valhalla then so much the better.
While many are difficult to find and a bit more expensive to purchase than "ordinary" stock, that is to be expected. Rare means rare. On the other hand, their self-sufficiency also equates to lower feed and vet bills and less labor intensive attention. As a plus whatever doesn't go into the cook pot can be sold to bring a small income stream into the project.
We're looking at several major categories of livestock and poultry to have on Valhalla. Naturally these will be phased in over time. I've already been to the movie where 250 animals are waiting for pickup and the farm isn't ready for them! Since the second kick by a mule is not a learning experience we'll definitely have our act together on the receiving side and bring them in slowly over time.
Species under consideration are the following: donkeys, cattle, sheep, goats, pigs, chickens, turkeys, ducks, geese, rabbits, and honeybees. Raising quail and pheasant is being researched. Our jury is out on horses. They seem like awfully big eaters for little return. We'll see in time.
We'll have to have guard animals for the predator issues, and donkeys and dogs top that list.
We're going to post some information on all these species including specific breeds we're looking at and why on these pages.


Jan 16 - Last week for our current websites!
If you have your eye on a video at Women Smoking Culture, SmokeVision, Model House or ModelsUpClose websites, now is the time to buy it - next week it will be gone!
It is time for us to make the move to a brand new web platform, the move has been in planning for a long while and I had in mind the end of February for the change over but it is being forced on us now by technical changes at our current delivery service. Our current sites won't be updated but does function normally, so you can buy what you see there now or as long as you see it there.
Progressively over the coming week or two we will migrate to the new platform and you will notice a totally new look, that will be better on tablets and mobile devices too. I am hoping that a lot of our current shows will eventually return there but that will take a long while to build up again - sigh!
Our last major change of platform (five years ago) took us 'off the air' for months as the web techs consulted their navels as to why it didn't work the way it should - so if we do go away suddenly we will come back, just as soon as we figure why something didn't work the way it said it would in the manual - gulp!
And keep reading the Smoking Culture Google Group for exclusive access to new videos we are expecting next week - if you sign up to this Google Group you can set preferences to get email alerts whenever we make a news post and not miss the new stuff.


Nelson Bricklayers (BB9): The standard strategy when looking at home improvements which require any sort of brickwork is to get in touch with a professional Nelson bricklayer. There will not be that many property owners in Nelson will be blessed with the confidence and expertise to take on this kind of work themselves, and consequently using an expert is unquestionably a sensible move.
Don't let yourself be tempted to cut corners with your building tasks around the house and garden by supposing that bricklaying is an easy job. There are many subtleties and trade secrets which can cause a less knowledgeable amateur in Nelson to make errors and even the smallest building job, for example a garden wall can end up being dangerous.
An experienced bricklayer will be glad to offer you the best advice on every aspect of your brickwork project in Nelson, including guidance on materials, timescales, and costs. This might be for anything from a brick barbecue to a full scale property extension. Be grateful for this advice and use it well.
There are other reasons to emphasise why it's ill-advised to use an untrained or novice bricklayer for your brickwork assignment. It isn't simply a case of getting the bricks laid but also of recognizing all of the variables that relate to the process. A couple of examples of this could be that a specialist will recognize the significance of ventilation, airtightness and the thermal capabilities of particular materials, will be mindful of the currently available materials, and which are most suited to any job in question, and will give thought to waterproofing, environmental considerations, and humidity regulation.
Professional Nelson bricklayers will not only be specifically trained to complete the task correctly and safely, but will additionally be armed with the right tools, the knowledge of contemporary construction techniques and all related work-related safety and health considerations to ensure the safety of your build.
Getting instruction throughout their working life, a professional bricklayer ought to have concluded vocational training, NVQ's and other qualifications and certificates in the building industry which show their skill at the mastering of this age-old profession. Previous to beginning any project in Nelson they will talk about your exact needs and expectations so as to offer a detailed quote and all work should really be backed by a guarantee to offer peace of mind to you.
Try to find bricklayers in Nelson who are members of trade organizations for example the Federation of Master Builders, the National Federation of Builders, the British Standard Institution (BSI), the Fair Trade Association and the Guild of Builders and Contractors. If you've got any issues with regards to a particular tradesman, whether it be regarding his working standards or his alleged qualifications and experience, then you could contact the Guild of Builders and Contractors and inquire if there might be any ongoing grievances against them. Taking these kinds of measures ought to ensure you select the ideal Nelson bricklayer for your construction project.
Stonemasonry Nelson: Certain aspects of stonemasonry are comparable to bricklaying, whereby it relates to the laying and shaping of natural stones rather than man-made ones. As a craft or trade stonemasonry has been used for hundreds of years and Nelson stonemasons ply their trade to the restoration, conservation and repair of buildings, bridges and monuments which are made of natural stone. If your house in Nelson is made of natural stone rather than brick, you may need to bring in a local stonemason in Nelson, if you have repair or remodeling work that requires attention. While stonemasonry is a very skilled occupation there are not any formal qualifications needed to enter the trade. The required skills are generally mastered on the job and you will find 2 types of stonemason carrying out this sort of work; banker stonemasons and fixer stonemasons. Banker stonemasons are based in a workshop, while fixer stonemasons work on-site.
Mortar Joint Profiles: There are actually numerous distinct profiles for mortar joints used in stonemasonry and bricklaying, including the bucket handle joint (or concave), the weather struck joint, the recessed joint, or the flush joint, you may hear of others (ie: beaded, extruded, or vee), but those mentioned are the most widely used ones. The most commonly used mortar joint in the UK is the concave (or bucket handle, where the exposed face of the joint is compressed producing the most resilient profile you can get.
Brick Arches Nelson: Brick arches have been used in buildings for centuries and can be added for both decorative and structural purposes. There are of course numerous styles of brick arch, including segmental, Venetian, gothic, Roman, semicircular, horseshoe, multicentred, tudor, bullseye, jack and more. You will need to employ an exceptionally competent bricklayer if brick arches are to be included in your project, so be certain that whomever you hire knows exactly what he's up to, and has previous experience with the type of arch that you want.
Also find: Roughlee bricklayers, Brierfield bricklayers, Barrowford bricklayers, Colne bricklayers, Reedley bricklayers, Worsthorne bricklayers, Briercliffe bricklayers, Foulridge bricklayers, Newchurch-in-Pendle bricklayers, Fence bricklayers, Wheatley Lane bricklayers, Barley bricklayers, Trawden bricklayers, Burnley bricklayers, Blacko bricklayers, Little Marsden bricklayers, Winewall bricklayers, Padiham bricklayers and more.
More Lancashire bricklayers: Rawtenstall, Skelmersdale, Poulton, Lancaster, Chorley, Lytham St Annes, Colne, Nelson, Preston, Ormskirk, Fulwood, Morecambe, Burnley, Blackburn, Penwortham, Darwen, Heysham, Accrington, Fleetwood, Leyland and Blackpool.
Bricklayers in other areas: Burslem, Solihull, Northwich, Glenrothes, Retford, Slough, Marlow, Greenock, Chatham, Chester, Sunderland, Bushey, Burntwood, Bath, Wolverhampton, Abingdon, Yeovil, Billingham, Aldridge, St Neots, Winsford, Falmouth, Derby, Pudsey, Canvey Island, Rotherham.
A brief look on the internet produced the following results for "bricklayers Nelson Lancashire": M Schofield Construction BB9 7UG, ASG Construction BB9 9PA, Jonny Wilmore Construction BB10 1DZ.
Some Nelson locations covered by Nelson bricklayers: Cracoe Gill, Coppice Close, Beddington Street, Bradshaw Close, Springfield, Bradley Hall Road, Churchill Way, Alder Bank, Thorne Street, Canal Mews, School Street, Caldervale, Taylor Street, The Ridgeway, Avondale Road, Barleyfield, Boothman Place, Albert Street, Sheridan Street, Clement View, Chatham Street, Colne Road, Dixon Street, Stone Croft, Ann Street, Bradley Road, Summer Street, Cliffe Street.


text:
YOUR-VOICE
Compassion, kindness: Recalling the first Jewish High Holidays after the liberation of Paris
Mel Corren
Special to The Stockton Record
When those dark years under the German occupation were over, the Jewish High Holidays once again were being observed at the famous Grand Synagogue of Paris, Rue de La Victoir, where Allied soldiers along with those Parisian Jews lucky enough to have survived, came together to worship.
My buddy, Bob Rieders, and I, both sadly and joyfully, joined the remnants of the Jewish people in France when they observed the first Rosh Hashanah, the Jewish New Year, since the Nazi occupation.
When we entered the crowded Synagogue, we noted that several of the front row pews were left empty in memory of those deportees who would never return. This display of reverence and acknowledgment brought tears to our eyes, as well as to the many others in the congregation.
Assembled on that memorable occasion were, along with the remnants of Parisian Jewry, Allied Servicemen of all types and uniforms, including the top brass of the European Allied Command. And when the Kaddish (the Hebrew memorial prayer) was recited the feelings it evoked were beyond description. I felt they included grief, thanks, disbelief and a good measure of guilt. The latter, we later understood, was suffered by many of those who survived, for having done so while family members and friends had perished.
The next week was Yom Kippur, and Bob and I decided not to go to the Grand Synagogue again, opting instead for a smaller one.
We took a taxi to a location shown on our map but were lost until a man came along and in broken English/Yiddish asked if we were Jewish and were looking for the synagogue. I told him in Yiddish that we were, and he took us on foot through a few short streets to a shul (small synagogue) near the Bastille (before the war this was a very Jewish neighborhood).
The services were already in progress, so we took a seat amid welcoming stares from the congregation.
Afterward, the rabbi asked the congregants to welcome the American soldiers present and invite them to their homes for the "uhp fahst" (the breaking of the fast). Bob and I walked to the rear of the room where we were immediately surrounded by a sea of people asking about the United States and asking us if, by chance we knew their relatives who lived there. They had no idea of the size of the United States.
Suddenly, an immaculately dressed man pushed his way through the crowd, yanked on Bob's sleeve, and said in broken English, "You come wiz me. My wife speaks English!"
Bob led him through the crowd to me, and we explained that we were a pair and wanted to stay together. He told us that it was not a problem – we could both come. He explained that his wife, who was from England, would be thrilled to have English speakers in their home. (Can you imagine a young English/Jewish woman coming into that hornet's nest as a bride?)
After stopping for an aperitif, we reached his apartment, where we found his wife and their son awaiting the arrival of their husband and father.
When we entered, we fell into each others' arms and proceeded to talk, eat and drink.
They explained that they had taken their baby for a walk when the trucks came to pick up the Jews in the neighborhood, and fortunately, their neighbors did not turn them into the Gestapo. They told us how difficult it was with their infant son cooped up in their small apartment, and how, at times, they had to put swaddling clothes in the baby's mouth so as not to call attention to themselves.
The man's former boss, the owner of a tailor shop, risked his life by bringing him work and returning with food when he picked up the finished products. It was a Schindler-type operation on a small scale. One hand washed the other, but there would have been severe consequences had they been caught.
That night, they gave each of us the yellow Stars of David they had been required to wear, to identify themselves as Juives (Jews), during the occupation.
When we left these folks that night, after hearing about how they were shielded by their neighbors, we were, again, reminded that even in those darkest hours, compassion and human kindness still existed.
Mel Corren, 96, is a lifelong Stockton resident.

redpajama_set_name: RedPajamaCommonCrawl


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text:
School of Management Staff
Accounting and Finance Staff at the School of Management
Dr Hanh Nguyen
Boubaker, S
Buckle, M
Nguyen, H
Cai, Y
Davies, L.P
Elbakry, A
Elmagrhi, M.H.A
Erkaboev, A
Evans, P.S
Fan, R
Fantini, G
Filer, T
Gedikli, C
Halabi, H
Hawkes, A.G
Huang, F
Jia, Y
Jones, S.J
Li, H
Liu, X
Miller, A
Ojra, J
Pryce-Brown, T
Rudkin, W
Shabi, S
Shabi Ul Hassan, S
Spender, E.T
Tran, L
Tsakou, K
Upreti, V
Virk, N
Williams, T
Yilmaz, O
Zaki, A
Zhou, T
Li, Z
Business Management Staff at the School of Management
Economics Staff at the School of Management
Professional Services Staff at the School of Management
PhD Students at the School of Management
Lecturer in Accounting, Accounting and Finance
+44 (0) 1792
JavaScript is required to view this email address.
hanh-nguyen-1726b79b
Available For Postgraduate Supervision
Hanh is a Lecturer in Accounting at the School of Management, Swansea University. Hanh joined Swansea University in August 2021. Prior to joining the School of Management, Swansea University, Hanh held positions as Research Assistant for Essex Business School, University of Essex and Teaching Assistant for UCL School of Management, University College London. While doing their PhD at University of Southampton, Hanh worked as Research Assistant for a project funded by ESRC, tutor in Accounting.
Hanh completed their Doctoral studies in Accounting at Southampton Business School in 2021, with School winner for Doctoral College Research Award 2021. Hanh holds an MSc with Distinction (University of Huddersfield), and a BSc with First class (National Economics University, Vietnam) in Banking and Finance.
Hanh has presented their research at a number of national and international conferences, workshops, and seminars in various countries. Hanh is also a frequent ad hoc reviewer for a number of international journals, such as Business Strategy and the Environment.
Accountability and Disclosure
Environmental management accounting
Quantitative and qualitative research
Teaching Interests
Award Highlights
Hanh has substantial teaching, examining, tutoring and supervising experience in a wide range of academic and professional accounting subjects for both accounting and non-accounting students, such as Financial Reporting and Statement analysis, Research Design and Analysis, Accounting for Economics, and Introduction to Accounting and Finance for Engineers at both undergraduate and postgraduate levels in a number of national and international universities.
Hanh has continuing research interests in accounting and governance (corporate governance, board diversity, financial reporting, and corporate finance) and accountability and disclosure (environmental management accounting). Hanh has articles published in leading international journals, such as the International Review of Financial Analysis, Business Strategy and the Environment, amongst many others.
Doctoral College Research Award 2021
School Winner
Southampton Business School
Taught Modules
MN-1021 Accounting for Economics
To introduce students to the fundamentals of financial and management accounting. Accounting is of critical importance in support of all business activities so this course is designed to introduce the basic concepts on which accounting is based, providing students with a toolkit that enables a better understanding of the performance of businesses and the decisions and problems they face.
MN-M009 Financial Reporting and Statement Analysis
The module is designed to give students an understanding of financial reporting and how financial statements are prepared. Students will consider the usefulness of financial statements and financial statement analysis in decision making.
Research Assistant, Department of Accounting, Essex Business School, University of Essex
March 2021 - July 2021
Teaching Assistant, UCL School of Management, University College London
Senior Lecturer, The University of Finance and Business Administration, Vietnam
October 2015 - October 2016
Lecturer, The University of Finance and Business Administration, Vietnam
December 2010 - August 2014


With the weather changing, we all know what is coming (if you haven't seen it already): snow. The white flurries that fill the sky and make us grumble at times is on its way to bring snow days, snowball fights, snow angels, and best of all: snowmen. While we can't bring these creations inside, we can bring replicas of some of them into our classrooms to help create a winter wonderland of snow! There are several ways to bring happy little snowmen (and women) into your classroom with fun winter crafts that can be fun and educational; here are my top 7!
#1 Shape It: If you are working with your students on shapes, you can have them create a snowman using a variety of shapes for different parts of their body. Here's what your directions could look like.
Make three circles! A big one, a medium sized one, and a small one.
On a different color of paper, make a long skinny triangle.
On another color of paper, draw three small squares that are about the same size.
On the same color paper you drew your squares on, draw five teeny, tiny circles.
On a new color, draw two long skinny rectangles and three short skinny rectangles.
Now cut out all of your pieces and put your snow man together.
Optional: Add a scarf and a hat.
#2 Save the Melting Snowmen: Have you ever done an escape room with your students before? This is a fun math game that gets students working together, solving puzzles, and doing math. Your kids will be so engaged, they won't even realize they are doing math! This game is available for 1st-5th grades.
You can also find this game in digital form for 3-5 grades!
#3 Show the love: Another way to make a snowman in your classroom is to print out an outline of a snowman and give students cotton balls. If you want to turn this into a character lesson, you can have students color their cotton balls any color they would like. You can talk about how each of the snowmen are different, but they are all snowmen regardless of what they look like. This can be a lesson in how being different doesn't make you bad or wrong. Then have all of your students add a heart to their snowmen to remind us of the most important part of people: their heart.
#4 A Roll of the Dice: This is a great way to make a snowman while playing a game. Create a worksheet that has all of the parts of a snowman (the eyes, mouth, nose, arms, hat, and scarf) and assign each part a number. Have students roll the dice to see who can complete their snowman first. This is another great character activity. This game gives you the opportunity to talk about being a good sport and being happy for others even if you are not doing well (which is a skill we all need).
#5 Combine STEM with an Escape Room: If your students love STEM/STEAM activities, and escape rooms, why not combine them both? In this game students will be building a catapult to help the snowmen who are vacationing at the beach, make it back to the snowy mountains before they melt. This game is available for lower and upper elementary grades.
#6 Play it up: With the activity, you can teach kids how to collaborate, write, and create fun and interesting characters! Put students into groups of three or four, whatever works best for your classroom. Then ask them to give each of the snowmen a personality that can be portrayed through something they have on. For example, students might say a snowman is grumpy because he has a red scarf or lucky because his scarf is green. Then have your students write a play and perform it with snowmen puppets they make from a popsicle stick, small white plates, and construction paper. If you wish, you may also use dowel sticks in place of popsicle sticks.
#7 Snack Time: A fun activity to do with students is a craft they can eat. You will need marshmallows, pretzel sticks, chocolate chips (or any other kind of small candy), and white frosting. Have students use frosting as glue to put three marshmallows together. Then put the sticks into the sides for arms. Finally, use the frosting to put the chocolate chips and any other candy on there to give your snowman some fun physical features.
There are so many ways to bring some snowman fun into your classroom. Make every activity a fun learning activity that not only gives your students a fun snowman, but also teaches them about shapes, character, math, and more!


ALBANY - Albany community schools recently announced its high school and middle school honor rolls for the first quarter of the 2015-2016 school year. (* indicates a 4.0.) Albany High School Honor Roll 12th Grade High Honors: Emily Hauri, Sydnee Woyak, Ciearria Mortaloni, Alexandra Lent, Halie Lyons, Tyler Dahl, Clay Spooner, Andrew Berra, Josh Little and Jacob Lyle.


Tattoo fanatics might refer to tattoo designs as "ink", "pieces", "skin art", "tattoo art", "tats", or "job"; to the developers as "tattoo musicians", "tattooers", or even "tattooists"; and to places where they function as "tattoo design shops", "design studios", or "tattoo parlors".
Tatts would seem truly awesome, offered a bunch of thought has actually entered into choosing your design, as well as based accurately on the understanding that this is an irreversible marking on your body.
With a little bit of investigation on the style, some prep work and a really good, gifted design musician, the result of this particular sort of tattoo ought to be actually nothing except a sensational, vivid and also wild work of art.
Traditional tattoos are actually normally described in dark, then filled out through black shading or even various other colours combined along with dark ink.
Think me, There are actually great deals of design styles in this planet and also you can discover quickly one excellent tattoo design for students.
If students adore the concept, don't be actually terrified to acquire a design that doesn't possess a deeper interpretation.
Right now there are a whole lot of well-known design musicians as well as a bunch of elegant, gorgeous as well as classy layouts out certainly there. Fantastic tattoo designs will certainly influence you to obtain your very own ink performed simply discover out more regarding the developers and also the stories behind them.
Old as well as historical tattoos are going to certainly never head out of design in designs globe.
For tattoo design abusers, complete back tattoo designs are actually commonly their needs while lower back tattoo designs are typically really loved through charming and attractive ladies.
One of the most popular strategy from tattooing in contemporary times is actually the electrical design device, which inserts ink right into the skin layer using a solitary needle or even a group from needles that are fastened over a bar, which is connected to an oscillating device.
Whether they're inking a concept you've given all of them, deciphering your short in their very own means or even food preparation students up something totally coming from scratch, they are actually called design artists for a cause.
Tattoo design concepts could be combined in to a custom part that will certainly be appreciated for a life time.
If students are actually getting a design considering that you're higher or even drunk, defiant or even your pals are proding you, after that students are actually obtaining a design for all the wrong explanations and also the selection students make is likely to mirror this inadequate from provision.
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Trump announces social distancing guidelines extended to April 30
President Trump said Sunday the peak in the death rate from the coronavirus pandemic is likely to hit in two weeks and extended guidelines to slow the spread of the deadly illness for 30 days.
"The better you do, the faster this whole nightmare will end," Mr. Trump said during a briefing of the White House Coronavirus Task Force from the White House Rose Garden. "Therefore, we will be extending our guidelines to April 30 to slow the spread."
The president said his administration would be finalizing social distancing guidelines on Tuesday. He said he does not anticipate the restrictions will be relaxed by region.
Coronavirus: The Race To Respond ›
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"It's very important that everyone strongly follow the guidelines," he said, adding that he believes the country will be "well on our way to recovery" by June 1.
Mr. Trump had previously suggested he wants to reopen the U.S. economy, which has been battered by the coronavirus outbreak, by April 12. On Sunday, he said that date was "aspirational."
President Trump speaks during a Coronavirus Task Force press briefing in the Rose Garden of the White House in Washington, D.C., on Sunday, March 29, 2020.
Dr. Anthony Fauci, the nation's top infectious disease expert and director of the National Institute of Allergy and Infectious Diseases, said the mitigation efforts currently underway are having an impact on combating the spread of coronavirus and lauded the decision to extend the social distancing guidelines.
"The decision to … extend this mitigation process until the end of April I think was a wise and prudent decision," he said.
The Centers for Disease Control and Prevention has urged Americans to follow social distancing measures, including by working from home and limiting social gatherings to no more than 10 people. The clock on the White House's guidelines, which Americans were told to follow for 15 days, was set to expire Monday.
There are more than 135,000 confirmed cases of the coronavirus in the U.S., according to Johns Hopkins University. More than 2,400 people in the U.S. have died of the illness, including an infant in Illinois, considered to be the youngest fatality.
The U.S. now ranks above Italy and Spain for the highest number of coronavirus cases.
Dr. Deborah Birx, the White House coronavirus response coordinator, said modeling shows that between 80,000 and 160,000, with as many as 200,000 Americans, could die from the coronavirus even with mitigation.
"We're hoping the the models are not completely right, that we can do better than what the predictions are," she said.
In addition to implementing measures designed to limit the spread of the coronavirus, the Trump administration has also been working to extend testing and securing personal protective equipment for health care workers on the front lines, to be delivered to the states.
Mr. Trump said the Food and Drug Administration on Friday authorized a new test from Abbott Laboratories that will deliver coronavirus results in as soon as five minutes and said the U.S. would begin delivering 50,000 tests daily this week.
"We've been doing more testing than any other country in the world," Mr. Trump told reporters during the briefing in the Rose Garden, adding the number of tests administered is the reason the U.S. has more confirmed coronavirus cases.
"Deployment of rapid testing will vastly accelerate our ability to monitor, track and contain the viruses," Mr. Trump said. "We will defeat this virus."
The president also detailed the new treatments being administered to patients who have tested positive for the coronavirus, including hydroxychloroquine, which along with the Z-Pak is being administered to 1,100 people in New York. The FDA is also allowing seriously ill patients to receive an experimental convalescent plasma treatment, which involves taking blood from recovered patients and transfusing it to those who are sick.
Mr. Trump seemed to question the uptick in demand for personal protective equipment such as N95 masks, asking if they are "going out the back door?"
States have also warned of a shortage of ventilators for those suffering from the coronavirus, though the president suggested hospital chains were "hoarding" ventilators.
"Many of the states are stocked up," he said. "Some of them don't admit it. We have sent just so much, so many things to them, including ventilators."
The federal government, however, is keeping 10,000 ventilators in the Strategic National Stockpile "to hold in case of emergency," Mr. Trump said.
In addition to federal guidelines, states have also been imposing their own restrictions on residents as they rush to stop the spread of the coronavirus, including by ordering nonessential businesses to close and residents to stay in their homes.
On Saturday, Mr. Trump said he was considering a quarantine on the New York metropolitan area, which is currently the epicenter of the outbreak in the U.S., but he later abandoned the idea.
Instead, the president directed the Centers for Disease Control and Prevention to issue a "travel advisory."
The advisory urges residents of New York, New Jersey and Connecticut to refrain from non-essential domestic travel for 14 days effective immediately. It does not apply to residents working in "critical infrastructure industries" such as trucking, public health, financial services and food supply.
Mr. Trump told reporters public health experts suggested a quarantine of the New York area, but he believed it was "too much to do" and difficult to enforce.
To alleviate the economic impacts of the coronavirus outbreak, the president has signed into law three legislative packages, including a $2 trillion economic stimulus package passed by Congress last week. The legislation provides direct payments to American workers, as well as loans to small businesses and large industries hurting because of the coronavirus.
Mr. Trump did not rule out a fourth relief bill, telling reporters he is "prepared to do whatever it takes to save lives and to bring back our economy."
The president also said he would take another coronavirus test "if it's appropriate," and said he hasn't experienced any symptoms associated with the illness.
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This modern chair and will bring a contemporary style into your home's decor. Accenting button and welting details give a unique look to the set. The sinuous wire suspension system of the chair and webbing of the ottoman offer comfort and support. Exposed wooden legs can be finished in your choice of color to accompany your choice of upholstery. This chair and ottoman set will be the perfect place to kick your feet up and relax.
The Claire Contemporary Chair and Ottoman by Rowe at AHFA in the area. Product availability may vary. Contact us for the most current availability on this product.
N760-006 Chair 1 35" 34" 32"
N760-005 Ottoman 1 30" 22" 19"


Home/Autism, Education/Able Academics' Students Thrive!
Able Academics is a school for children on the Autism Spectrum and their families. This school blends both academic and behavior services. This meld allows students to receive support behaviorally while receiving quality educational services. Able Academics has two locations in Titusville, Florida. The Main Campus is located at 2063 Garden Street and serves student in Kindergarten to the twelfth grade. The second site is located at 5056 S. Washington Avenue. This location is dedicated to early intervention for children from two years old to the third grade. Both locations strive to ensure that students receive a well-rounded education that includes individualized education services, Specials classes, Applied Behavior Analysis, and opportunities to build upon their knowledge through our Science, Technology, Engineering, and Mathematics (STEM) programs.
Students have an opportunity to participate in fun, hands-on enrichment activities. They participate in Art, Music, Life Skills, or Yoga classes on a daily basis. By offering these classes, students thrive not only in traditional academics, but also find unique ways to express themselves.
In art class, students complete a variety of art activities. Students learn about different artist throughout history and utilize their techniques to complete art projects. They've learned about Michelangelo and created pictures on the "Sistine Chapel" ceiling by lying under their desk to paint. They've learned about Jackson Pollack and made splatter paintings. They've also learned a variety of art techniques such as lines, perspective, and shading.
Another enrichment class is Life Skills. In Life Skills, our younger students learn how to clean up such as, washing clothes and folding laundry. They have learned to wash dishes, collect trash, and other chores to help at home. Older students learn skills to prepare them for adult life, such as balancing check books, creating a budget, and staying on that budget. In addition, they learn job skills. For example, how to complete a job application, a resume, and interviewing skills. All students also learn cooking skills and kitchen safety. Students at Able Academics cook in our full kitchen and learn to make a variety of foods. These classes prepare students live full, independent lives as adults.
Yoga classes are very beneficial for the students. In yoga class, students learn techniques to cope with frustration and how to self-regulate their emotions. They improve their fine and gross motor skills. Students learn to overcome sensory overload by utilizing calming music and low lighting. In addition, yoga allows students to become more aware of their bodies and their movements.
Students participate in music classes twice a week at Able Academics. During music classes, students learn instruments such as guitar and drums. They also learn vocal skills by singing along to their favorite songs. Through these music classes, students develop confidence and a greater self-esteem. Even non-verbal students find ways to display their musical skills and express themselves.
One of the highlights of Able Academics is its inclusion of Science, Technology, Engineering, Math (STEM) activities each week. Research has shown that students with Autism often gravitate towards STEM fields. STEM activities allow students to develop their natural curiosity, creativity, and problem-solving skills. Students are provided a set of materials and given an engineering challenge. They work individually or in a small group to complete the challenge. Examples of STEM activities students have completed are building catapults using popsicle sticks, a spoon, and rubber bands, and creating the tallest tower utilizing only jelly beans and toothpicks. By completing these activities, students have learned to communicate with each other, construct a plan, and follow through each determined step.
Able Academics is a school dedicated to supporting students as they grow and find their way into adulthood. They are committed to providing quality education not only in the traditional school subjects, but also throughout their enrichment program.
To schedule a tour of Able Academics call 321-888-3020.
By Bright Feats|2019-04-02T17:46:38-04:00April 2nd, 2019|Autism, Education|Comments Off on Able Academics' Students Thrive!


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The FBI is fighting a losing battle over phone snooping
The FBI is fighting a…
The FBI says it wants a golden key to access Americans' phones. Now, politicians are pushing back.
A top FBI official, Amy S. Hess, said at a House Oversight Committee hearing on Wednesday that encryption of phone data is limiting the FBI's ability to spy on communication. She said law enforcement needs a way to access smartphone content in order to stop criminals and terrorists, suggesting that the FBI have access to keys that can unlock customers' data.
But in a rare show of unity, Congressmen almost universally fought back against that idea.
U.S. Representative Rod Blum, a Republican from Iowa, likened that to homebuilders putting a camera in every new house — and telling people to blindly believe they won't be turned on later.
"Isn't this analogous to that?" Blum asked Hess. "You're saying, 'Trust us, we'll only do it if we'll need to do it.'"
This hearing is the latest sign of a potential turning point. After the Sept. 11, 2001 terrorist attacks, a nation in turmoil passed security-focused laws like the Patriot Act that widely expanded the use of secret surveillance.
But sentiment is starting to shift in the other direction. In 2013, we learned that government spies are collecting emails, phone records and tapping into phone and video chats.
Tech companies, feeling betrayed, are encrypting more of their own communication — and offering that to customers too, guarding them from hackers, cybercriminals and government spies. Apple (AAPL, Tech30) has enhanced the security of iPhones by requiring a person's password to unlock his or her phone. Google (GOOGL, Tech30) allows Android users to encrypt their phones — but not by default.
When a phone is encrypted, law enforcement can't secretly search someone's phone remotely. Police need the physical device and a warrant. And — theoretically — detectives need someone's cooperation to go through their device.
The FBI says encryption of data shields kidnappers and pedophiles from cops. Hess reiterated this Wednesday, saying encryption has "a tremendous impact on our ability to fight crime and bring perpetrators to justice."
"If these devices are encrypted, the information they contain may be unreadable to anyone but a user," she said. "The process of obtaining a search warrant… could be an exercise in futility."
But in reality, cops can get into your phone if they grab it. Local police in Fort Lauderdale and Orlando told CNNMoney that devices exist to pull the data off smartphones, then hack into it.
Matt Blaze, one of the nation's top encryption experts, told members of the committee that breaking into an encrypted phone is a cinch. It'll take 10,000 tries to get past a four-digit passcode.
"On modern computing hardware, essentially no time at all," Blaze said. Seconds maybe.
Still, some law enforcement officials remain opposed to this level of personal privacy. Dan Conley, the top state prosecutor in Boston, criticized Apple.
"When corporate interests place crucial evidence beyond the legitimate reach of our courts, they are in fact granting those who rape, defraud, assault or even kill a profound legal advantage over victims and society," Conley said. "So, I'm here today to ask Congress to intervene."
U.S. Representative Ted Lieu, a Democrat from California, wan't having it.
"Why do you think Apple and Google are doing this? It's because the public is demanding it … a public that doesn't want an out-of-control surveillance state," Lieu said. "This is a private sector response to government overreach."
There's another reason to keep phones encrypted: If the FBI can get in, so can hackers.
That's an often misunderstood notion about security: Encryption isn't a dial. It's more like an on/off switch. It either works (by keeping everyone out) or it doesn't.
Category: Tech Alerts May 5, 2015
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If you need an easy, no-frills sugar-free ice cream, the following recipe is about as easy as it gets. It's based on the Philadelphia technique of ice cream making and you don't even need a bowl to mix the ingredients.
Measure the 2 cups of sucralose in a measuring cup. Pour enough half-and-half into the measuring cup to dissolve the sucralose. (It will dissolve easily.) Add the salt and the peppermint extract to the measuring cup and stir. Pour this mixture back into the half-and-half container and shake to combine. Store the mixture in the back of the refrigerator for at least an hour to make it as cold as possible.
When the mixture is ready, freeze it in your ice cream maker using the manufacturer's directions.
This ice cream will be a bit granier than an ice cream made with sugar.
You can experiment with the amount of peppermint extract letting taste be your guide.
Copyright © 2012 - 2017 by David Fisco. All rights reserved worldwide. Requests for licensing and distribution can be emailed to David Fisco.


text:
<?php

namespace DTS\eBaySDK\ResolutionCaseManagement\Types\Test;

use DTS\eBaySDK\ResolutionCaseManagement\Types\IssuePartialRefundResponse;

class IssuePartialRefundResponseTest extends \PHPUnit_Framework_TestCase
{
    private $obj;

    protected function setUp()
    {
        $this->obj = new IssuePartialRefundResponse();
    }

    public function testCanBeCreated()
    {
        $this->assertInstanceOf('\DTS\eBaySDK\ResolutionCaseManagement\Types\IssuePartialRefundResponse', $this->obj);
    }

    public function testExtendsBaseResponse()
    {
        $this->assertInstanceOf('\DTS\eBaySDK\ResolutionCaseManagement\Types\BaseResponse', $this->obj);
    }
}

redpajama_set_name: RedPajamaGithub


At some point in our life, we may all experience a minor obsession that is neither incapacitating or inconvenient. However, for a person suffering from OCD... the obsessions can become persistent, intrusive and infringe on their everyday life.
If you are someone who suffers from OCD you will likely find your obsessions are recurrent thoughts, doubts, fears and impulses that dominate your mind. Often leaving you feeling you have no control over these thoughts.
These compulsions are repetitive behaviour and you will find you perform the compulsion in accordance to 'rules'. Although you may believe the action pointless or ridiculous you cannot resist the compulsive behaviour. You are likely to experience increased anxiety if you resist and will find performing the action reduces that feeling. Unfortunately, this reinforces and compounds the compulsion.
There are many other symptoms, most of which will require you to carry out a form of ritual and may occupy several hours each day. Clinical Hypnotherapy and Self-Hypnosis can be used to induce calmness and reduce the level of anxiety experienced, helping you to overcome your obsessive compulsive behaviour.
If you believe you suffer from OCD and would like help overcoming your compulsive behaviour, contact us to arrange an appointment or to discuss further.


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« May 2022 | Main | August 2022 »
UK Bill of Rights set to undermine UK_GDPR and Adequacy
A fortnight ago, the Government published its UK Bill of Rights to replace the Human Rights Act 1998 (HRA).
My main conclusions concerning the Bill of Rights relevant to data protection are:
The Bill changes who interprets the meaning of necessity, public interest and proportionality and thereby changes the nature of the link between the UK_GDPR and A.8 of the European Convention of Human Rights (right of respect for private and family life etc).
The Courts do not undertake the balancing tests associated with "proportionality", "necessity" and what is "in the public interest"; these tests are undertaken by Ministers if a Government has a Parliamentary majority.
The Bill is a significant risk to the Adequacy Agreement with the European Commission.
The Bill protects the powers of the State from challenge, rather than protecting the individual from the misuse of State powers.
The Bill is intellectually flawed with respect to its treatment of A.8 issues.
The Bill allows Government to fashion wide ranging exemptions from the UK_GDPR, not listed in A.23 of the UK_GDPR; it also explicitly permits processing that breaches A.8.
The Bill neither addresses nor resolves the serious data protection issues identified by the ICO in his evidence to the MoJ Consultation.
The Commissioner might have misled Parliament in his recent Oral Evidence.
The Bill is intellectually flawed
Suppose legislation requires a public body to disclose specific items of personal data with another controller. Under the current data protection regime, such a disclosure would be "necessary for a legal obligation" (the controller's A.6 legal basis for the disclosure).
Additionally, such legislation that demands disclosure would also have to be justify its interference of the A.8(1) right in terms of "necessity" and "proportionality" as required by A.8(2).
Note that currently the two regimes (DP & ECHR) are firmly linked through the word "necessary" which has the same meaning in both regimes. So, in our example above, the ICO can consider whether the test of necessity in human rights terms, applies to the disclosure of personal data in data protection terms (i.e. whether the disclosure is really necessary for a legal obligation).
Under the Bill of Rights, this is not possible. Processing becomes "necessary" because Ministers have used their Government majority to enact legislation, approved by Parliament. The Courts have to give the greatest possible weight to the assumption that Parliament has balanced all the factors associated with necessity (and proportionality and in the public interest) when enacting that legislation.
In summary, under the Bill, Parliament determines the balancing concepts such as of necessity, proportionality or the public interest in legislation as it passes through its Parliamentary stages. This contrasts with the current position where the Courts (or ICO) consider such concepts, once legislation has been enacted.
The difference in timing exposes an intellectual shortcoming in the Bill of Rights. The Bill's position is that Parliament considers concepts such as "necessity" as the legislation passes through its Parliamentary stages (i.e. the legislation is not yet an Act of Parliament).
This is to be compared with the current position where legislation has been enacted, but its operation in practice has created a human rights difficulty which is being considered by the Courts.
In other words, balancing the concept of "necessity" etc is currently considered by a Court in the context of knowledge of all relevant facts. Under the Bill, Parliament considers such concepts in the absence of any fact.
This is hardly a rational approach towards enacting trouble-free legislation.
Unlawful processing is OK!
Suppose a future piece of legislation, passed by Parliament, requires a public authority to process specific items of personal data items it already holds for a new purpose Z, disclose them another organisation for purpose X. Assume further the Bill of Rights is an Act of Parliament.
All these processing activities are lawful, necessary, proportionate and in the public interest because the provisions of Bill of Rights requires the courts to assume Parliament has considered all the relevant balancing factors.
Indeed the Bill of Rights goes further, as it allows a public authority to process personal data in a way that is incompatible with a Convention right.
Although the Bill states that "it is unlawful for a public authority to act in a way that is incompatible with a Convention right" (e.g. the act in question being to process personal data as described above), this prohibition does not apply "as a result of one or more provisions on primary legislation, the authority could have not acted differently" (See Clause 12(2) of the Bill).
As the processing in the above example is required by law, the public "authority could have not acted differently". It follows that, if processing of personal data is required by law, it does not breach A.8 and never can be an unlawful breach of A.8.
If this interpretation carries over to the UK_GDPR, it serves as an exemption from the lawfulness requirements of the UK_GDPR and permits unlawful processing.
Why call it an exemption?
Suppose Parliament enacts a law which states that personal data have to be retained for seven years, when in practice the retention time should be one year. The text of the Storage Limitation Principle states that personal data shall be "kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed".
Note that the current test of "necessity" is linked to the "purpose of the processing". Because the word necessary has the same meaning in the human rights and data protection regimes, the question the ICO could explore under the current regime is: "In the context of this seven year retention period, is the law that requires such retention, proportionate and necessary?".
Under the Bill of Rights this question is not even asked. This is because it is presumed that Parliament has struck an appropriate balance between competing factors (e.g. proportionality, public interest, necessity) in approving this seven year retention period. Indeed, the ICO is obliged to give Parliament's balance "the greatest possible weight" if he were to enforce the Storage Limitation Principle.
In other words, the prospect of enforcement for seven-year-retention is remote. If an UK_GDPR provision cannot be enforced, then the provision itself is effectively exempt. In the case above, the Storage Limitation Principle is effectively exempt for seven years.
In general, the Bill's impact on the UK_GDPR is profound: any legislation if it contains provisions that relate to the processing of personal data, fashion future exemptions from the data protection regime, far beyond the requirements of A.23 of the UK_GDPR which requires any exemption to be "a necessary and proportionate measure in a democratic society" (where it is assumed the Courts assess the underlined words).
If you want an example of legislation that contains many such processing provisions which are likely to conflict with the UK_GDPR, see S.12 of the Childrens Act 2004. The ICO will have obvious difficulties in enforce UK_GDPR standards if the standards set out in S.12 differ.
Protecting powers not humans
It is important to understand, the UK Bill of Rights does not grant rights to protect individuals from the abuse of powers by the State. Instead the Bill protects the powers of the State from individuals who currently argue in Court that such powers have been unlawfully exercised.
This objective is achieved by making it more difficult for an individual to commence a Court case under the UK Bill of Rights. If, for example, Ministerial or public authority powers are misused, the complainant has first to show "significant disadvantage" from the misuse of powers.
Then the individual has to overcome the very strong presumption that the Minister (or public authority) is acting lawfully, proportionally, in the public interest etc. If the issue under scrutiny accords with legislation enacted by Parliament (which has considered all relevant balancing factors remember!) and if the controller is a public authority that has no choice, then the use of these powers is not a breach of A.8. (See the section on Unlawful processing is OK above).
If, perchance, an individual complainant then took the case to the Strasbourg Court of Human Rights and won, the Bill of Rights ensures the UK Courts and Government can effectively ignore that Strasbourg jurisprudence (see next section).
That's why the Bill protects the powers of the State from interference from data subjects and does not protect data subjects from the excessive use of State power.
How the Bill protects state powers
There are three procedural changes, targeted at the courts, that also protect the powers of Ministers or of the State from scrutiny. These are set out in Clause 1 of the Bill of Rights.
"it is the Supreme Court (and not the European Court of Human Rights) that determines the meaning and effect of Convention rights for the purposes of domestic law" (Comment: this allows future "Strasbourg jurisprudence" concerning the use of powers to be ignored);
"courts are no longer required to read and give effect to legislation, so far as possible, in a way which is compatible with the Convention rights" (Comment: this permits UK Bill of Rights to diverge from existing human rights precedents and existing Strasbourg jurisprudence; it also removes the requirement to ensure that an interpretation of any legislation is supportive of human rights);
"courts must give the greatest possible weight to the principle that in a Parliamentary democracy, decisions about the balance between different policy aims… are properly made by Parliament" (Comment: this allows Government, via its Parliamentary majority, to constrain further the Courts drawing a conclusion that a particular right has been infringed when powers are used).
The Explanatory Notes to the Bill state that a court must understand that "judgments, decisions and interim measures" of the ECHR "are not part of domestic law" and that the Principle of Parliamentary democracy (i.e. what Parliament enacts) is expected to prevail unless a case before the Court is exceptional.
As Government is in control of the Parliamentary agenda (e.g. Government Bills tabled before Parliament are usually enacted), another way of summarising the Bill's impact is as follows: "the powers that Ministers specify for themselves in legislation is what Parliament decides in terms of the Bill of Rights". And "what Parliament decides is what the Courts must give the greatest possible weight".
A shorthand for this is: under the Bill, "Ministers propose; the Courts dispose".
Adequacy down the tubes?
The Adequacy Agreement between the UK and European Commission mentions the current Human Rights Act over 50 times and assumes that the:
"… United Kingdom's adherence to the ECHR … as well as its submission to the jurisdiction of the European Court of Human Rights" is assured. (my emphasis). Comment: as can be seen from the Bill of Rights, the UK will be no longer "submitting" to the jurisdiction of the European Court.
"….any person that considers that his or her rights, including rights to privacy and data protection, have been violated by public authorities, can obtain redress before the UK courts under the Human Rights Act 1998". Comment: this is no longer true as the Bill of Rights imposes a significant threshold on the person seeking redress to show that he/she is a "victim" of an action that results in "significant disadvantage" to that person (Clause 15(3) of the Bill).
there is "continued adherence to such instruments" (e.g. "submission to the jurisdiction of the European Court of Human Rights"). ". Comment: The Bill of Rights ensures that "continued adherence…" is no longer the case.
So what are the implications of the above for Adequacy?
Does the above mean that the UK will lose the Adequacy Agreement immediately? Answer: "NO" as the Bill has yet to pass through Parliament.
Does the above mean that the European Commission could argue that the UK is set to renege on the Adequacy Agreement? Answer: "YES", and at any time.
Could the European Commission set in motion the steps needed to revoke the Adequacy Agreement? Answer: "YES", and at any time.
You don't need to take my word for it: the ICO could not be clearer in his evidence to the MoJ: "In order to maintain EU adequacy decisions, the Government should ensure its proposals continue to effectively implement the ECHR in British law"; para 4.23).
How necessity etc is determined
Article 8 of the ECHR contains the balance between the right to respect for private life (A.8(1)) versus the lawfulness of any interference with that right (A.8(2)). This raises the question of whether or not any interference is "in the public interest", "necessary" or "proportionate".
Clause 7 of the Bill of Rights sets out the role of Parliament in assessing these concepts when balancing different objectives (e.g. in A.8)). It states that when a Court is a considering whether there is a breach of a right, it must "strike the appropriate balance" between:
"different policy aims" (e.g. as in A.8(1) and A.8(2) ECHR). Comment: the Explanatory Notes says this also "includes weighing up competing social and economic considerations";
"different Conventions rights" (e.g. as with A.8 and A.10 ECHR);
"the Convention rights of different persons"; or
"a combination of matters mentioned in (i) to (iii)" Comment: the Explanatory Notes says this, includes balancing "a person's Convention rights" against "the interests of society at large".
In striking that "appropriate balance", a Court must (i.e. NO flexibility here):
"regard Parliament as having decided, in passing the Act" (i.e. the Act under scrutiny by the Courts), "that the Act strikes an appropriate balance" between the matters as set out in (i)-(iii) above; and
place "the greatest possible weight" on the principle that "in a Parliamentary democracy, decisions about how such a balance should be struck are properly made by Parliament".
In the context of A.8, the Courts must assume Parliament has considered different policy aims (e.g. whether the law enforcement authorities can access a database of personal data). Such consideration will naturally include concepts such as necessity, in the public interest and proportionality.
It can be seen that the courts will find it very difficult to diverge from this "appropriate balance" as it has to give this balance "the greatest possible weight".
This difficulty also applies to the ICO when enforcing the UK_GDPR.
The ICO published a trenchant criticism of the MoJ Consultation document of the impact of the Bill of Rights on the UK_GDPR (see references). Since then Information Commissioner has gone quiet on this impact.
The Commissioner might think that the problems he raised in his submission to the MoJ about "in the public interest", "necessary" and "proportionality" have gone away. They haven't. Whilst these were explicit in the MoJ Consultation, they are implied in any detailed analysis of Clause 7 above.
Indeed, when the Information Commissioner was last before MPs, he said the following in relation to a direct question about the Adequacy Agreement: "As I say, when the European Commission comes to look at the law and examine it, I hope that it will see everything that guarantees a sufficient level of protection of Europeans' data in the United Kingdom" (Q287; see references).
I can't see how the Commissioner has reached this conclusion. The statement to Parliament is, in my view, misleading.
Autumn Data Protection Courses
Because of continued COVID uncertainty, the following courses can be attended in person, or via Zoom, or as a mixture if you something untoward happens. It's up to you.
The next Data Protection PRACTITIONER Courses is in London on Monday September 19-24 (5 days); full details by emailing info AT amberhawk.com
The next Data Protection FOUNDATION Course is in London on Tuesday, July 12-14 and November 15-17 (3 days); full details by emailing info AT amberhawk.com
Link to all UK Bill of Rights documents: https://www.gov.uk/government/publications/bill-of-rights-bill-documents (you will need the Bill & Explanatory Notes)
Link to ICO's Human Rights response to the MoJ (a must read): https://ico.org.uk/about-the-ico/consultations/ministry-of-justice-consultation-human-rights-act-reform-a-modern-bill-of-rights/
The link to my four blogs on the MoJ human rights Consultation (see end of): https://amberhawk.typepad.com/amberhawk/2022/03/omissions-in-human-rights-proposals-degrade-privacy-and-freedom-of-expression.html
All the draft Oral evidence transcripts (the ICO one quoted above is 8th June) can be found on: https://committees.parliament.uk/work/1733/the-right-to-privacy-digital-data/