S o u th Ay rs h ire Co u n c il F o l l o w - u p In s p e c t i o n R e p o r t O c t o b e r 20 0 4 Contents ________________________________________ Page Introduction i 1. The aims, nature and scope of the inspection 1 2. Changes in the operational context of the Education Service 1 3. Continuous improvement 2 4. Progress towards the main points for action 6 5. Conclusion 17 Introduction The education functions of each local authority in Scotland will be inspected between 2000 and 2005. Section 9 of the Standards in Scotland’s Schools Etc. Act 2000 charges HM Inspectorate of Education, on behalf of the Scottish Ministers, to provide an external evaluation of the effectiveness of the local authority in its quality assurance of educational provision within the Council and of its support to schools in improving quality. Inspections are conducted within a published framework of quality indicators (Quality Management in Education) which embody the Government’s policy on Best Value. Each inspection is planned and implemented in partnership with Audit Scotland on behalf of the Accounts Commission for Scotland. Audit Scotland is a statutory body set up in April 2000, under the Public Finance and Accountability (Scotland) Act 2000. It provides services to the Accounts Commission and the Auditor General for Scotland. Together they ensure that the Scottish Executive and public sector bodies in Scotland are held to account for the proper, efficient and effective use of public funds. The inspection team also includes an Associate Assessor who is a senior member of staff currently serving in another Scottish local authority. All inspections of the education functions of educational authorities are followed up by inspection teams, normally around two years from the date of the original published inspection report. i _______________________________ South Ayrshire Council Follow-up Inspection Report 1. The aims, nature and scope of the inspection The education functions of South Ayrshire Council were inspected during the period April to June 2002 as part of the national inspection programme of all education authorities in Scotland over a five-year period. The local authority prepared and made public an Action Plan, indicating how it would address the main points for action identified in the original HMIE inspection report published in August 2002. An inspection team revisited the authority in June 2004 to assess progress made in meeting the recommendations in the initial report. 2. Changes in the operational context of the Education Service Since the initial inspection of the education functions of South Ayrshire Council, there had been some important changes within the Council and in the Education, Culture and Lifelong Learning (ECLL) Department. At the time of the initial inspection, the Council administration was led by the Labour Party. Following the local government election in May 2003, no party had an overall political majority with Labour and Conservatives each having 15 councillors. After applying agreed legal procedures, Labour retained leadership of the Council. Changes in personnel since the original inspection included the Convenor and Vice 1 Convenor of the Lifelong Learning Committee, the key policy and decision-making body for education. The political leadership of the Council demonstrated a continuing strong commitment to supporting, and scrutinising the work of the ECLL Department. At corporate level, a Chief Executive had recently been appointed and further changes in the Council’s departmental structure were being considered. There had been a number of changes in the ECLL senior management team. At the time of the follow-up inspection, two members of the Departmental Management Team were undertaking, in an acting capacity, the roles of two former Heads of Service. The Director had taken the opportunity to realign responsibilities across the Department and had created two new posts of Senior Quality Improvement Officers (SQIOs). The number of Quality Improvement Officers (QIOs) had been increased slightly, to allow each to be linked to a cluster of schools. All officers had very clear roles and responsibilities with an appropriate focus on promoting effective learning and teaching across the authority. 3. Continuous improvement Since the publication of the initial inspection report, the education authority had continued to improve its overall effectiveness. The Convenor and Vice Convenor of the Lifelong Learning Committee had made valuable contributions in supporting the ECLL Department in its work. The Department had further strengthened the impact of its aims, vision and values. It had taken effective action to ensure its core values of ‘honesty, respect, responsibility, equality and compassion’, permeated all aspects of its work. It had encouraged schools to identify and articulate their core values and was drawing on these values in shaping the authority’s plans and school development plans. The follow-up 2 inspection confirmed that the Department’s focus on further improving the quality of consultation and self-evaluation was making a positive impact. In a commendable initiative to further strengthen the Department’s approaches to consultation, groups of ‘critical friends’ had been identified. These groups comprising mostly, but not entirely, of headteachers, had been consulted for their views on a wide range of the activities of the Department. They had provided valuable advice which had assisted senior managers in evaluating the impact of current and new initiatives. Overall, staff employed centrally, headteachers and staff in schools felt that they had important roles in contributing to the work of the Department. Pupils also had regular opportunities to contribute their views, and appreciated the opportunities to influence their own educational experiences. The Department had engaged in wide-ranging consultation on four major policy documents which underpinned its vision for education and provided a clear sense of direction and purpose. These documents appropriately identified the Department’s current and future priorities for development. Priorities included improving the school estate, developing key aspects of the authority’s work on social inclusion, and strengthening the quality of leadership and management, learning and teaching, and ethos in schools. The Department’s commitment to improving the quality of education was clearly demonstrated in the strong focus on professional development and on the roles, responsibilities and expectations of staff. The Department had further strengthened its approaches to quality assurance. In addition to the well-established and rigorous Directorate visits to all schools, the acting Head of Educational Attainment and the Head of Educational Resources now followed up these visits as appropriate. They returned to schools and departments to 3 provide further support and challenge in areas identified as underperforming. These follow-up visits focused very effectively on identifying the causes of specific weaknesses and the approaches to be adopted to secure improvements. Raising attainment and promoting wider achievement were key priorities for the Council. Improvements in the strategic management of lifelong learning included important developments in joint working with other Departments and agencies to improve the quality of services for children and to promote success in various contexts. The impact of the improved arrangements was seen in, for example, increased attainment levels of looked after children. The Department had implemented a number of initiatives which were successfully meeting pupils’ needs by offering alternative curricular pathways to other stages of education or employment. For example, in partnership with The Prince’s Trust, seven secondary schools were providing a two-year course for pupils in S3/S4 which included aspects of citizenship and interpersonal skills, community awareness, preparation for the world of work, entrepreneurship, and a residential experience. The Department had also extended the range of initiatives undertaken in partnership with Ayr College to include, for example, well-designed vocational courses for pupils from Social Inclusion Partnership areas. In the above examples, good use of curriculum flexibility had increased the motivation of pupils to achieve success in preparation for further study or employment. In addition, a strengthened emphasis on promoting and celebrating success included wide recognition of pupils’ achievements in aspects such as enterprise education, drama, music, and in a range of national awards. Figures for 2003 indicated that the performance of pupils in primary schools and at S2 in reading, writing and mathematics had remained above the national averages 4 and those for comparator authorities. Data for 2004 indicated that in all measures of performance in S4 to S6 the authority’s figures were above the national averages, and broadly in line with those for comparator authorities. During the period since the inspection of the education authority, HMIE had carried out a number of school inspections and follow-through visits. In primary schools, the overall quality of attainment in English language and mathematics had been maintained and was good or very good in almost all schools. Many of the subject departments in secondary schools were performing well. In all sectors HM Inspectors found improvements in approaches to planning and assessment and to school self-evaluation, and the quality of leadership had remained consistently high. The Department’s performance in following up main points for action from HMIE reports was very strong. All schools that had received follow-through visits demonstrated improvements in the quality of provision for pupils. Link officers had worked effectively with the schools to support and challenge them in improving performance. Follow-through inspections and moderation visits to schools demonstrated that they had the capacity to further improve, and had made good or very good progress towards meeting the main points for action identified in the original inspection reports. Overall, and with particular reference to its work in further strengthening elements of consultation and self-evaluation, the ECLL Department had demonstrated a continuing commitment and a clear capacity to improve the quality of its support and challenge for schools. The impact of the Department was seen in evidence from school inspections which confirmed improvements in the effectiveness of schools’ approaches to self-evaluation. In a ‘showcase’ during the follow-up inspection, staff and pupils from schools across the authority provided very positive evidence of the impact of some of the authority’s initiatives in addressing national priorities of raising 5 achievement and attainment and promoting social inclusion. 4. Progress towards the main points for action The initial inspection report published in August 2002 identified five main points for action. This section evaluates the progress the authority has made with each of the main action points and the resulting improvements for pupils and other stakeholders. 4.1 Procedures for the development and review of central staff and the devolved management of resources should be strengthened. The education authority had made good progress in strengthening the effectiveness of procedures for the development and review of central staff. Very good progress had been made in improving arrangements for devolving resources to schools. The Council’s policy for professional development and review had been extended to include all centrally-deployed staff within the ECLL Department. Links between the Council’s Human Resources and ECLL Departments had been strengthened through the collaborative work of Officers. In addition to working with central staff, she was liaising with school cluster administration managers to finalise the roles and responsibilities of school-based support staff in the development and review process. The ECLL Department had taken appropriate steps to ensure that the new arrangements provided a meaningful review experience and appropriate development opportunities for all staff. It had delivered training courses to raise awareness of procedures and timescales for implementation. While this process had taken some time, the system was now firmly in place and was being 6 implemented effectively in well-planned phases. All centrally-deployed officers had received useful training in the review process. The Director, Heads of Service and almost all central staff had been reviewed. In addition, significant improvements had been made to the professional development and review process for teaching staff in schools, with firm plans in place to re-launch the programme at the start of session 2004/2005. Improvements in the professional development and review procedures had begun to assist centrally-deployed staff improve their effectiveness. Interviews were systematically recorded, collated and prioritised with a clear focus on addressing staff development needs. An increased range of opportunities was available for central staff to take part in working groups, to engage in job shadowing activities, and to share their expertise more widely. Award bearing courses, including Scottish Vocational Qualifications, had been made available to all levels of staff. As a result of these measures, centrally-deployed staff were now in a stronger position to support improvements in the quality of education across the authority’s schools. Arrangements for the devolved management of resources had been improved significantly. Since the original inspection report, the Council had established a revised scheme for the delegation of funds. The new arrangements were very clear and had been well received by schools. In particular, improved arrangements for viring funds gave schools greater flexibility in carrying forward and making effective use of surpluses from one year to the next. Schools had also appreciated improvements related to greater transparency in the allocation of funds and earlier notification of the finance available. On a broader front, the Council had also made very good progress in bringing all schools into the corporate 7 financial system. This had significantly increased the quality of financial information available. Following a restructuring of central staffing dealing with finance, clear links had been established between the ECLL Department and Financial Services. Support for ECLL from finance staff had been strengthened by an increase in the number of staff and in their levels of expertise. In recognising the importance of working closely with Financial Services, the ECLL Director had included senior finance staff in his extended Departmental Management Team. Their inclusion at this strategic level assisted finance staff to keep in close touch with educational developments. Overall, the level of financial advice and support available to assist the authority and schools achieve their aims was now very good. The improvements in financial arrangements had made a positive impact on schools. With improved access to financial information and increased flexibility in their use of devolved finances, headteachers were now able to plan improvements for pupils more systematically and effectively. 4.2 Senior managers in the Education Culture and Lifelong Learning Department should further develop the expertise and skills of link officers in supporting and challenging schools. The ECLL Department had made very good progress in addressing this main point for action. The Director had acted quickly to consult with headteachers on proposals to strengthen the support and challenge role provided by link officers to schools. Following this consultation exercise, the role of the link officer had been re-defined with a sharper focus on securing school improvement. The number of QIOs with link officer responsibilities had been increased and all of the officers had undertaken a comprehensive, well-planned and valuable training programme. The 8 programme had helped to further develop officers’ skills in monitoring and evaluating the work of schools and in analysing and using performance information effectively. Link officers had benefited from shadowing experienced senior officers on quality assurance visits to schools. The Department had taken the significant step of setting up the Quality Development Unit to provide a lead in promoting and supporting improvements in the standards and quality of provision across all of the education functions of the Council. The Unit was continuing to gather and disseminate a very useful range of statistical data to assist schools in evaluating their effectiveness. Building on the existing very good framework for quality improvement, the acting Head of Educational Attainment and a SQIO had taken action to underpin key aspects of the quality improvement processes with more efficient and effective management information systems. The acting Head of Educational Attainment provided excellent leadership and support to link officers. He had played a key role in training link officers and had ensured that they were well equipped to carry out their quality improvement roles. All link officers had a clear understanding of their remits and were carrying out their roles very effectively. They had established very good relationships with schools and had given valuable support through assisting with school self-evaluation, reviews, development planning and monitoring, and commenting on standards and quality reports. They had contributed to clear improvements in the rigour and consistency of schools’ self-evaluation processes and in the quality of reporting on standards and quality. Link officers now played a more active role in assisting schools to prepare for the Director’s visits to establishments and to respond to the points for action agreed after these visits. Staff in schools appreciated the support provided by link officers. 9 There was clear evidence that the greater levels of support and challenge provided by link officers were having a positive impact on the quality of pupils’ experiences. Headteachers interviewed during the follow-up inspection confirmed that the effectiveness of link officers work had improved. Link officers had encouraged and supported collaborative working among clusters of schools and network groups to help identify and promote specific initiatives. Their work focused well on securing improvements for pupils in schools across the authority. Link officers had, for example, effectively supported improvements in the continuity of pupils’ learning from P6 to S2, and in working to raise standards of attainment at S1/S2 in English language and mathematics. Link officers were also making important contributions in helping schools implement authority-wide initiatives focusing on, for example, more coherent and relevant experiences for pupils in S3/S4. The strengthened focus on their quality improvement remit supported by a very good training programme, had enabled link officers to carry out their role more confidently and competently. All schools were benefiting from the increased levels of support and challenge provided by link officers. 4.3 Steps should be taken to improve the provision of staff development for teachers, and extend the arrangements to support probationers. The ECLL Department had made very good progress in addressing this main point for action. An extensive range of continuous professional development (CPD) activities was now available to all teaching and non-teaching staff. The Department had developed more effective systems for ensuring that the menu of training activities met the specific needs of 10 individual members of staff and the authority’s priorities for improving the quality of pupils’ experiences. The increased focus on the needs of individual schools and their pupils was an important feature of the improved arrangements for CPD. A systematic analysis of school development plans and departmental plans helped to identify CPD activities that related to schools’, departments’ and pupils’ needs. In mathematics and science, for example, working groups had supported the development of coherent authority-wide programmes of study to improve pupils’ experiences in these areas of the curriculum. The identification and collation of subject-specific needs was assisted by regular meetings of schools’ CPD co-ordinators and informed by meetings of lead principal teachers. In addition, the analysis of HMIE reports and the results of Director’s visits to schools influenced the menu of courses. The Council was also piloting courses focusing on additional support needs, with places offered to parents as part of that provision. The Department had reviewed models of delivery of CPD to offer greater flexibility. CPD provision now included twilight and week-end sessions. Shared activities within clusters of schools focused well on improving pupils’ experience of transition between pre-school and primary and between primary and secondary sectors. The focus on transition provided pupils with more coherent and progressive learning experiences in all sectors. Approaches to evaluating the effectiveness of CPD activities had been strengthened. Feedback from a range of stakeholders was closely evaluated and the Department provided follow-up reports to working groups and networks on action taken in response to feedback. The authority had significantly extended and improved its arrangements to support probationers. Each probationer was being supported by a nominated school mentor who had received appropriate training to undertake the role 11 effectively. An annual programme of events for probationers and mentors was well targeted on curriculum and generic issues relevant to all sectors. It also took very good account of the results of surveys of previous probationers’ views on strengths and areas for improvement. A series of network support meetings for probationers throughout the year provided a very useful forum for discussion of key issues. The Department had also produced helpful materials to support new staff in pre-school centres. Further developments included a co-operative venture with East Ayrshire Council in establishing a website for probationers. Positive evaluations by probationers of their experience in schools and of the quality of support provided by the authority confirmed that the ECLL Department had made significant advances in this aspect of its work. The authority’s focus on improving the quality of teaching was a key feature of its commitment to raising attainment. Evidence from school inspections, particularly with reference to improvements in approaches to planning and assessment, indicated that the provision of staff development for experienced and new teachers was making a positive impact on important aspects of teaching and learning. 4.4 Provision of ICT equipment and training for teachers in the use of ICT should be further improved. The authority had made very good progress in addressing this main point for action. The Council had invested heavily in the ICT network within education, providing additional funds to augment those allocated through the National Grid for Learning (NGfL) framework. This investment had significantly improved the average ratio of computers to pupils across the authority’s schools. The provision of computers in schools in all sectors now met national targets. 12 All schools now had high speed access to the internet. A new system was being introduced in schools to improve the management of information in aspects such as tracking attendance and recording pupils’ progress. Schools were finding some initial difficulties in operating the system, but recognised the potential benefits in various aspects of their work. The recruitment of a schools technology officer had been an important factor in securing strategic improvements in the use of ICT across the authority. He liaised very effectively with schools to ensure that modern technology could be used to best effect in learning and teaching. He chaired a number of strategic forums which included headteachers and ICT co-ordinators to discuss issues and initiatives to improve pupils’ experiences in using ICT. The ECLL Department had recently published its strategy for using ICT in learning and teaching. This document clearly and concisely documented the aims of the authority together with the roles and responsibilities of individuals in helping to achieve these aims. Particular emphasis was given to training staff in using ICT effectively with pupils. In addition to the investment in hardware, the Council had improved various aspects of support available to schools. The central helpline was now responding well to requests for technical support. Four technician posts had been created to support secondary schools. Three designated ICT support officers assisted establishments and individuals over and beyond the provision of New Opportunities Fund training for teachers and librarians. A wide range of training units and a corporate ICT training suite were now available to teaching and non-teaching staff. Very good arrangements were in place to respond to requests for one-to-one and group training. The authority had developed fruitful partnerships with national agencies to support 13 developments in using ICT in the context of provision for pupils with additional support needs, including aspects of behaviour management. Staff had also benefited from valuable training opportunities in the use of interactive whiteboards and digital cameras. Overall, the authority’s investment in these developments had made a very positive impact in schools. Teachers’ confidence in using ICT had been increased significantly. Network groups had focused on improvements to secondary subject courses, 5-14 developments, early years programmes, and provision for pupils with additional support needs. Staff who had participated in ICT Masterclass training were supporting valuable developments across the authority in enhancing pupils’ learning. Pupils were clearly benefiting from the developments. The opportunities to use an increased range of modern technology were considerably enhancing their learning experiences. 4.5 The Department should continue to focus on improving the curriculum and attainment at S1/S2, and should seek to further improve attainment in national examinations, particularly at Standard Grade. The ECLL Department had made good progress in addressing this main point for action. The Department had given high priority to improving the quality of the curriculum and attainment at S1/S2. It had successfully supported the development of programmes of study to support continuity and progression from P6 to S2 in specific areas of the curriculum. Approaches to improvement had included writing support materials, purchasing new programmes of study, seconding able practitioners as staff tutors, establishing working groups to support targeted developments, and employing educational consultants with expertise in specific areas. The ECLL Department had provided schools with a 14 helpful list of curriculum materials in use across the authority with a view to sharing good practice and facilitating improvements. It was making good use of the Council’s intranet as the main vehicle for providing access to curriculum resources. The Department had co-ordinated a review of assessment materials and encouraged staff in primary and secondary schools to work more closely together to ensure continuity in assessing pupils’ progress. In addition to his meetings with headteachers, the Director had met with networks of depute headteachers and principal teachers to discuss and review issues arising from the analysis of performance across subjects. Key areas and priorities for development were agreed with a focus on pupils’ performance at S1/S2 and in national examinations at S4 to S6 across the authority’s schools. Figures for 2001 to 2003 showed that the authority had been successful in improving attainment in S1/S2. At S2, in reading and writing, South Ayrshire’s performance continued to be above the national average figures and those for comparator authorities. The improvement in attainment in mathematics was a notable feature. In mathematics, the authority had improved from a position of being below national and comparator averages in 2001 to above these figures in 2002 and 2003. General strategies had included a closer focus on tracking and analysing pupils’ performance, setting targets, and devising improvement strategies. The particular emphasis on developing pupils’ skills in mental calculation and in using ICT had made important contributions to improved attainment in mathematics. In seeking to improve pupils’ performance in national examinations at S4 to S6, the ECLL Department had taken action to address a number of issues which had been identified as potential hindrances to effective learning and teaching. The Department had introduced greater rigour into quality assurance procedures relating 15 to the allocation of permanent contracts to teaching staff and to the evaluation of temporary staff. The increased availability of twilight or weekend CPD activities for staff aimed to improve continuity in teaching for pupils by reducing the extent to which teachers needed to be out of school. Significant increases in the allocation of resources to pupil support and inclusion had the purpose of improving the quality of learning for all pupils. The Department had designed these and other commendable initiatives with a clear focus on supporting improvements in the quality of pupils’ learning and in their attainment. The overall picture of performance throughout S4 to S6 indicated that the authority was continuing to sustain levels of attainment above the national averages. The performance of pupils in S4 to S6 had remained broadly constant over the last three years. The authority had maintained its position above national averages, but while performance at Levels 4 and 5 in S4 had improved slightly in 2004, there had been a slight decline in standards of performance at Level 6 in S5 and S6. In relation to the authority’s work in supporting inclusion, notable improvements had been achieved in the attainment of looked after children. Very good progress had been made between 2002 and 2003 in reducing from 60% to 22% the number of 16 and 17 year-old pupils leaving care with no qualifications at Level 3 or better. Similarly, with the same group of pupils over the same period, the authority had made very good progress in increasing from 10% to 56% the number who achieved Level 3 or better in English and mathematics. In both of these cases, South Ayrshire had significantly improved its position relative to comparator authorities and national averages over the last two years. The Department was continuing to give appropriate priority to supporting all pupils to achieve success in National Qualifications. The Department’s rigorous analysis of performance data, the Director’s visits to schools, follow-through visits and 16 interviews with under-performing departments and staff were indicative of a clear determination to improve performance. Following the Director’s strong lead, staff throughout the Department demonstrated a continuing focus on exploring ways of further raising pupils’ achievement and attainment. 5. Conclusion Since the publication of the inspection report in August 2002, the Director and his staff had made very good progress in strengthening the work of the authority in supporting and challenging its schools. Changes in the management structure of the ECLL Department had focused on improving the ability of central staff to provide a high quality service to staff and pupils in South Ayrshire schools. Since the initial inspection, the very good strategic management and the very high quality of leadership had been not only maintained but further strengthened. Following the Director’s impressive lead, senior managers and centrally-employed staff demonstrated that they had the skills to motivate staff in schools to give of their best for pupils. The extended Departmental Management Team showed a very strong commitment to improving quality through effective teamwork. Centrally-employed staff had benefited from an extensive range of opportunities to participate in or lead cross-departmental groups or working parties. The resulting increased sense of ownership and responsibility among staff was making a positive impact on the quality of education provided in schools across the Council. The Department had increased its support for teachers and probationers through important improvements in the provision of CPD. There had been significant improvements in the provision and use of ICT equipment across the authority’s schools, and considerable progress 17 in reviewing and developing the skills of central staff and teachers. The focus on meeting the wide range of pupils’ needs and promoting social inclusion was a particular strength. Initiatives and projects which encouraged pupils to achieve success were making a positive impact, notably in providing alternative curriculum pathways to motivate pupils to achieve success and to promote social inclusion. Overall, there was clear evidence to show that the authority had sustained and strengthened its capacity to ensure continuous improvement in the quality of its work. As a result of the overall very good progress made by the authority, HMIE will make no further visits to the education authority in connection with this inspection. Ian Gamble HM Chief Inspector Directorate 5 October 2004 18 How can you contact us? If you would like an additional copy of this report Copies of this report have been sent to the Chief Executive of the local authority, elected members, the Head of the Education Service, other local authority officers, Members of the Scottish Parliament, Audit Scotland, heads of the local authority educational establishments, chairpersons of the local authority School Boards/Parents Associations and to other relevant individuals and agencies. Subject to availability, further copies may be obtained free of charge from HM Inspectorate of Education, Area 1-B South, Victoria Quay, Edinburgh EH6 6QQ or by telephoning 0131 244 0747. Copies are also available on our website: www.hmie.gov.uk. If you wish to comment about education authority inspections Should you wish to comment on any aspect of education authority inspections, you should write in the first instance to Mr Ian Gamble, HMCI, at HM Inspectorate of Education, Room 1-B95, Victoria Quay, Edinburgh EH6 6QQ. Our complaints procedure If you have a concern about this report, you should write in the first instance to Hazel Dewart, Business Management Unit, HM Inspectorate of Education, T1 Spur, Saughton House, Broomhouse Drive, Edinburgh EH11 3XD. A copy of our complaints procedure is available from this office or by telephoning 0131 244 8468 or from our website at www.hmie.gov.uk. 19 If you are not satisfied with the action we have taken at the end of our complaints procedure, you can raise your complaint with the Scottish Public Services Ombudsman. The Scottish Public Services Ombudsman is fully independent and has powers to investigate complaints about Government departments and agencies. You should write to The Scottish Public Services Ombudsman, 4-6 Melville Street, Edinburgh EH3 7NS. You can also telephone 0870 011 5378 or e-mail enquiries@scottishombudsman.org.uk. More information about the Ombudsman’s office can be obtained from the website: www.scottishombudsman.org.uk Crown Copyright 2004 HM Inspectorate of Education This report may be reproduced in whole or in part, except for commercial purposes or in connection with a prospectus or advertisement, provided that the source and date thereof are stated. 20