A Hard Day’s Journey Into Light – A Case Study of Moving From Reactive to Proactive Risk Management

Niel Nickolaisen

CIO at OC Tanner

Amy Knapp

Director Service Delivery at OC Tanner

Learning Objectives

Please Join the CIO & VP, Information Security and Compliance of OC Tanner, Niel Nickolaisen & Amy Knapp in this Executive Interview where they will discuss the steps, they took to become more proactive in the midst of dramatic changes in the market, client requirements, regulatory change and its own manufacturer-to-technology company transformation. OC Tanner had to overhaul an upgrade it approach to information security, privacy, and risk.


"The risk had never really been part of what the company looked at from a security or privacy perspective. Everything was a risk."

Niel Nickolaisen

CIO at OC Tanner

Amy Knapp

Director Service Delivery at OC Tanner

Transcript

Britt Erler

Hello, and welcome to the CIO VISIONS Leadership Virtual Summit hosted on Quartz Network. My name is Britt Erler, QN Executive Correspondent. Thank you so much for joining us. I am pleased to welcome our executive speakers, Neil Nickolaisen, CIO, and Amy Knapp, VP of Information Security and Compliance with OC Tanner. Today, they will be sharing their insights and the steps they took to move from a reactive to proactive risk management. Welcome both.


Neil Nickolaisen

Thank you very much.


Britt Erler

It’s a pleasure to have you here and really thrilled to dive into this topic today. Before we do so, if you both wouldn’t mind giving a little bit of insight about your current roles and your backgrounds.


Neil Nickolaisen

Sure. Like you said, I’m Neil Nickolaisen, CIO at OC Tanner. OC Tanner is a legacy manufacturing company focused on employee recognition programs primarily for the fortune 5000. The market dynamics had changed. They started a digital transformation and brought me and then I, being the purse smart person that I am, knew that the first thing I had to do is bring Amy Knapp with me to OC Tanner seven years ago, to help them transition from being entirely a manufacturing company to a software and an HR technology company. That’s what we’ve been working on for the last seven years.


Amy Knapp

As Neil said, my name is Amy Knapp, and I’m a VP of Information Security and Compliance, which has been an evolved role since I joined seven years ago. My background was primarily in IT operations. That is an area that we really needed some help in and I acquired the Information Security team when I joined. That was a change for me, but also a big change for OC Tanner as we move forward with what we needed to do.


Britt Erler

Fantastic. Well, welcome to you both. Thrilled to have you here. Neil, I’m gonna kick it off to you, when you started, what was the situation and condition?


Neil Nickolaisen

OC Tanner, in employee recognition programs, we end up consuming and using our clients’ employee data files, we know a lot about their employees. The security of that data mattered a lot. The security really had two elements to it, our internal security and privacy, making sure we’re doing things right, but then particularly for our clients, because they wanted to make sure that we’re protecting the data that they were providing us. Now, when we got there, we did, we were did kind of the bare minimum of compliance and mostly interactive way. The focus on security and privacy was really ramping up for our client, and we were not very well prepared to deal with it. We weren’t reacting very well, we weren’t responding very well. If a client or a prospective client would ask us, how do you do this, we are typical as far as what we don’t at all. Confronting that, we knew we had to make some changes, not just in our operations, our internal processes and our tools, but also how we interacted with our clients, and also with the company. We were as it was, if somebody asked us to do something, we would think about doing it, and if we did it, we do just that. Everything was entirely reactionary, and not really thought out well or planned for the future, or how to get ahead of the game rather than just always be responding to either a complaint or request.


Britt Erler

What were the immediate changes that you felt you needed to make?


Neil Nickolaisen

First of all, we had to change our attitude in terms of just as a company. Rather than something we’re forced to do, this is something we need to do, and we want to get good at it. And so, the first thing we did was sort of a risk assessment. The risk had never really been part of what the company looked at from a security or privacy perspective. Everything was a risk. Now, let’s evaluate the risk on likelihood and impact. Let’s focus our attention on the higher risks, not the lower risks. Let’s get our act together with the basics—the blocking and tackling. One of the things I’ve always looked at from a compliance perspective, whether it’s PCI or Sarbanes Oxley, or FERPA, or whatever it is, if you’re doing the right things, compliance shouldn’t be an issue. At the same time, compliance wasn’t the goal. It’s an outcome because you’re because you’re doing the right things. We started with what frameworks do we want to adopt? What are the gaps we have? Then those gaps don’t inform us on how to become compliant, they inform us on things we should be doing anyway. Compliance then becomes a natural part of just are doing things well.


Britt Erler

Amy, what changes did you make?


Amy Knapp

We were also very much an information security team at NARU, and so it was enforcement not enablement. Changing that aspect to be able to further promote what the organization needed to do, but also still secure us as well was a big piece of that culture shift for the team. The team that we had at the time was also very much the police police in the police. They were doing a lot of the administrative work and a lot of the hands on stuff, as well as being the advocates of the advisories. I worked towards being able to kind of separate those duties so that we didn’t have any of those conflicts, which is usually a sign of maturity in terms of how you progress in security. For a long time, it was just kind of a like a side group of people that weren’t really that much of a focus. It was there because it had to be. It was there because the questionnaires kept coming from clients and the security questions kept coming, as Neil said the reactionary aspect to it. The gap analysis was mandatory for being able to work through what it was that we were actually doing, and where we were missing certain key aspects. Then it was a case to look at how to bridge those gaps. We did actually do some movement with some people in that area. We kind of rebuilt that team, probably about six months after I arrived based on the skill sets and the need for the organization and that reframing. We basically moved some of the people that were really hands on deep into certain areas, into those areas that should have been owning that in the future, so a little bit of a shift in personnel.


Neil Nickolaisen

Going on as an example, we had somebody that was sort of an audit of network security without, let’s get ahead of it by putting that person who knows so much about network security on our network team. Let them solve the problems at the root at the core, rather than being sort of a somebody who stands outside of the group and says you’re doing this wrong. If you know what to how to do it right, let’s have you do it right.


Britt Erler

Absolutely. I think that leads into my next question for both of you, what were some of the other specific things that you did to be less reactive and be more proactive, and make sure that this wasn’t just a short term plan, but something that was long-term?


Neil Nickolaisen

As I’ve thought about this, one of the things I learned a long time ago from Lean Manufacturing, is what is the role of testing in Lean Manufacturing. What you don’t want is a QA group, and this applies to software as well. What you don’t want is a group who’s looking to fix the mistakes others made. What you want is somebody who teaches the people that are building the stuff how to not make mistakes. In a perfect world, there are advisors rather than mistake catchers. We took the same approach, let’s look at our processes, and rather than having a group of auditors or group of checkers or mistake finders or mistake catchers, how do we have the people doing the work think about security and privacy in a way that they embed it in their work? We sort of started from a compliance perspective, we said this is the framework we’re going to adopt. Then we just over time worked on how do we make information security, data privacy, all the things we needed part of somebody’s daily work rather than something that was outside their daily work. If I could get them to build that into a clearly, it’s if I’ve got, we did the same thing or soft sauce software development. It’s better to have a Software Engineer never create a bug or if he does create a bug, catches own bug than hope a Software Tester catches the bug. Let’s take that same approach with everything that has to do with security and privacy. Let’s make sure people know what mistakes can happen, how to avoid those from happening to make sure that they never pass those mistakes on to somebody else. Over time, we shifted the role of our infosec and privacy teams to be these advisors and sort of process analysts and root cause analysts so that they could then push that back work back up to the front of how people did their work. I’ll let Amy add her thoughts on the same topic.


Amy Knapp

Another element for frameworks is IT Service Management, which usually tends to lend itself more to operations, but it can flow through effectively anything even from like HR activities through to facilities maintenance, and one of those things is just understanding that cycle. When we see that something is awry, why is it awry? Let’s work out how to fix it. How do we eliminate that from happening in the future? That becomes more innate in how people view problems is the systemic is just a one off? What do we do with this? How do we structure the process and or the parameters for dealing with that technology or that particular service so that we don’t see that crop up again? A lot of it was establishing those best practices, putting together checklists for repeatable tasks and things that we do, and that kind of flowed into our audit process as well. That was analyzing what our clients were looking for, how the market was shifting, what the adjustments were in terms of NIST and SKUs controls, and looking at our need for certification, which took us down the pathway of going after our SOC reporting—which is not SOCS—just to be confusing with acronyms, just throw them all out there. That was another aspect. It was going from reactive from the client, demanding that we do something to being able to analyze whether or not that actually suited our environment. A part of that was also understanding what that environment looked like. I don’t think I need to say that it people really don’t like writing things down. We’re not the most favored at documentation. That was another part of it, which was understanding the environments that we were actually supporting, and also protecting. Knowing what that makeup was, and kind of setting that ground for how to be proactive with those services, and also functions because not knowing what you have doesn’t help you to not be reactive. It was akin to kind of like walking through a graveyard in a zombie movie and being grabbed by things every now and again, because you just didn’t know it existed. As a Manufacturing company, we had a lot of time to learn aspects as well, that just didn’t crop up very often. You would have to find someone that had been working at OC Tanner for 15 years, and it seen this at least once in their lifetime. Then you’re like, what is that? Half the people around you are like, “I don’t know, I’ve never seen it before.” Making sure that you can account for those things. I think the other part of it was having people bring you things rather than finding them out, and creating that trust, where having an outage or having an issue isn’t something to be fearful of. You have to bring it to the fullest so that we can actually understand it and take care of it and make sure that, you know, it’s either removed from the environment or we know how to handle it instead of hiding it away. Being kind of fearful of that retribution incident type aspect, which sometimes exists in operational cultures.


Neil Nickolaisen

If I could just add to that, Amy brings up the really good point that we had to get good at root cause analysis. Oftentimes when there’s an issue, the IT’s response is “Let’s reboot the server and the problem went away.” No, the problem didn’t want to go away, the symptom went away. You have to dig deeper, ask why, what caused the problem that led us to believe that rebooting the server. If I had to reboot the server, we had just from a cost perspective, we had people who’d written scripts to automatically reboot the server because it was going to go down. Now, let’s get out of that business. Let’s find out what’s causing the problem. Let’s apply that across everything we do. If there are issues with security or privacy, let’s get to the root cause and find out where in the process, we need to change that process how far upstream so that this never comes back again. We just wanted to get out of the business of react being reactionary. In my perfect world, all work is planned, rather than reacted to. Each time you react to an incident, not only are you not doing your planned work, but your customers are stopped as well. Let’s eliminate all unplanned work, and the way you do that is improving your processes by eliminating the cost over time.


Britt Erler

I think that leads into my next question. With all of these changes, Amy, I’ll direct this one to you. How do these changes impact your personnel and what did you have to do to help them adapt and also make sure that you’re retaining that talent?


Amy Knapp

The hardest part is that some people just don’t like change at all. IT at OC Tanner had undertaken quite a bit of change in leadership, the years leading up to us joining and so, there was change fatigue. Also, let’s wait it out and see how long this person will last because there had been some shuffles in that area. There was resistance initially to some of the baseline changes. I also took on the Service Desk at the time, and a lot of that was in terms of just general ticket handling and customer service. Viewed as it being a hassle to log calls that they just fixed straight away, things like that. From a maturity aspect in that term, they were like, this is my work, and I’m like, well, actually, it should be the standard amount of work. To give that feedback to the client is where the value comes from, in actually having you exist as a team. It was trying to adjust to the expectations or the lack of expectations that were there in the past, and truly understanding the people that were involved in the change as well. I remember sitting down with the Service Desk team, like during my first two weeks and asking them what they want to do with their lives. I was just reflecting on this this morning, one of them said, “Well, I’m going to retire soon, so I don’t really have any future plans,” and he’s still here. He lied to me, but that’s okay. Things like that—understanding who they are, where, how they ended up where they are. As Neil said, one of them in Information Security team members, we actually did move him into the networking team, one of the other ones that we had, we moved him into our general infrastructure and operations team. Understanding what their motivation was and where their skill sets were, and then talking through why it made sense to move them to those areas, I can proudly say, they still talk to me. Obviously, we did a good job in it. It takes a lot of heart to make those changes. And maybe there isn’t a spot for them directly where they were. Our Services Manager at the time was not well cut out for that role and kind of just fell into it, and so we ended up having a conversation about what he really wanted to do. Ended up moving him into our Internal Manufacturing Support IT team and he just soared. Now, he’s in our Database Administration team. That move was so good to see. He can find his passion and realign to where he needed to be, which also helped us get somebody in to take on the role of the team management that really helped us mature in that area as well. I think it’s being open to the fact that some people fall into roles because of things that have happened, and some people are pushed into roles because they were good at x and certain now they leading y and it doesn’t make much sense. I think, as a leader, you need to be very aware of what opportunities you might have. Seeing potential in those people to be able to develop skills in other areas that you may have a gap in, and being open to the conversation that not everybody comes to work loving what they’re doing. There may be something else that is more akin to where they should be and you can help facilitate that growth, if you’re willing to actually do it.


Britt Erler

Yes, I completely agree. Neil, my next question for you is, what design steps did you take to make sure that you were constantly being adaptive to this unknown future that we’re experiencing?


Neil Nickolaisen

I think there are a couple of things. One is, Amy touched on a little bit just the culture, and really creating a culture of IT agility, oftentimes were perceived as, like Amy said, the “No” people. No, we can’t do that, we can’t do that. Okay, let’s ask ourselves from a culture and process perspective, how do we enable agility? The other thing from a design perspective, from an architecture perspective, I used to think the goal of any system is reusability. I’d like to build something once and use it multiple times. And I think, with the pace and rate of change now, which is all driven by technology, I think replace ability starts to trump reusability. From a process perspective, from a tool perspective, from a technology perspective, making sure things are loosely coupled. Our goal became enough loose coupling, that if we decided, let’s say, Endpoint Protection, we want to make change how we do Endpoint Protection, that that’s a decision we could make. The implementation of that could happen nearly immediately, because we wouldn’t blow up anything else around it, because nothing was tightly coupled to it. We took this loose coupling concept as far as we could go, not just with the tools we use, but with the processes we use, and the practices we use, then we tried to create this idea as part of our culture that we are, we’re technologists, that technology changes all the time. Therefore, we’re not going to wet ourselves to a certain way of doing things because we should be ready to change anything all the time anyway as well. Even even to the point of our roles, it’s okay. If we decided to replace this endpoint protection that you’re in love with, it’s okay, it’s not a bad reflection on you, it just means we’re making a change. Let’s not be change resistant as much, let’s be leaders of change. Because as technologists, it’s our life. There’s change happening around us every day. Let’s be the change.


Britt Erler

Now, Amy, what regulations apply to you?


Amy Knapp

The big four letter word of GDPR, obviously came in just over three years ago, for a lot of people. It was met with a little bit of skepticism from just the general populace of US because we’re not used to that type of level of regulation. As an organization, OC Tanner decided to really pursue, to be in the best spac we could be in on that date of May 25th 2018, which was ingrained in my brain. To make sure that we were kind of ahead of the curve, and it was one of those aspects where we saw a lot of our biggest clients that we expected to have already been on top of it come into the fore with it six months after it actually went live. It was commendable for us to take that chance, because there was, the absence of risk was, let’s see what will happen is, what some people would say, or it may not apply to us. Being a global company, we obviously had to take it into account. I think it’s put us in a better state for being able to deal with any of the other privacy regulations that have come along. When CCPA came along, it really didn’t impact us as much. Now with the CPRA, which is the secondary adjustment to that. We’re going to just be able to roll into it and setting our standards at that higher EU level, especially around privacy was a really good move for us to be able to keep that high level and just watch all the other regulations just kind of bump up against it. We were like, “Okay, we’ve got that covered,” so that was excellent in terms of of that regulatory aspect. Now, OC Tanner is a privately held companies, so we don’t have as many regulations to adhere to, but we’re very aware of what’s happening. While we don’t deal with healthcare data, we are very well aware of what the HIPAA requirements are. While we don’t have to deal with FERPA, we do have clients that have to deal with it. There are a lot of passed down regulatory aspects that we get to enjoy. That is not directly related to us as a business but to retain our clients who are in those realms, we have to be very mindful of it. It comes down to that nice balance of, you have to be aware that you may not have to meet all of it, but you also have to support your clients and being able to affirm you as a vendor to be able to utilize you and continue to use you. We try to keep an eye on privacy and security regulations that are changing in a lot of areas and keep abreast to the frameworks that are adjusting as well. A lot of what we utilize, I mentioned them a little bit before was NIST, CIS, we look at our ISO frameworks. However, we don’t actually pursue that certification. And then we have our service organizational controls SOC area, which is what we get recertified in each year, and that one plays a big part for us. Even though if you look at it from an IT perspective, a lot of people will pursue that ISO 27001. The SOC aspects are actually more applicable to our organization and their pure essence, so we’re aware of it, but we don’t necessarily follow it to the letter. In other realms, I mentioned ITIL and ITSM. That’s kind of my base bone for everything. I refer to it as the pirate code for IT operations. You take and choose and pick things. It’s always a nice guideline and a nice stability of where to work within, and then try to push yourselves out of that. I think from that baseline, it works really well to be able to take any area that might be struggling and look for ways to improve.


Britt Erler

This next question is for both of you, with all these changes and experiences that you guys have been through in the past years, as you look forward, what are your priorities?


Neil Nickolaisen

I think continuing what we’ve done. I would say if we’re, if we want to embed information, security, data, privacy thinking to all of our practices, I’m going to guess, I’m going to be optimistic. I’m going to say we’re 70% of the way where we need to be. I think we’ve still got more work to do. I still think the one thing I worry the most about is what I call the lone bonehead. We can have a lot of protections in place but one person who makes a mistake, even though they’ve never made a mistake before, but in this moment became a bonehead and did something they shouldn’t. How do we isolate the activities of a potential lone bonehead? I’m not sure how to crack that code, but for me that’s nirvana. Is the lone bonehead can do something boneheaded, and it won’t affect the rest of the organization or our data or anything else. I can quit and retire when I figured that out and probably as a multi billionaire, because others will want to know how we figured it out. The thinking for me is how do we get into the lives and processes and heads of everybody, so they don’t become a lone bonehead that hurts us.


Amy Knapp

Yes, my priority is making Neil not usable with boneheads so much and presentations in the future. Although he does usually refer to them as weenies, so I don’t know if that’s a step up or a step back. He’s right, like the weakest link is somebody, usually a person on the team that ends up being tricked and or persuaded to do something or thinks I’m just going to do this, and then forget that they did that and leaves an open hole. I think a lot of it is relationships, like and most people think that security is all about the tools, the bells, and whistles, you know, the ability to hack. A lot of it is actually just building relationships with people that can give you the information that you need to be able to act upon it. Tto think before they actually do something, is this something I should do? Maybe I’ll check with Amy and her team. A lot of that is also just when your proof of concept, you’re engineering something out, you’re like, “Okay, we need an X, let’s just go grab this and put it in,” and then it ends up becoming a viable product, and you still have X in there, and no one knows that you have x in there, and then you find it out later. Things like that, where the more culturally, you can just ingrain conversations around choices that are being made vendors that are being discussed, software that you’re looking at buying integration points, how your API is coming on board, what your separation of duties under your access controls are around people, making sure that you can limit the amount that some lone bonehead can do. Also, the monitoring aspect, and it’s this continual evolution of what you can automate, and also the detail that you can keep collaborating with the teams that you’re working with and throughout the business. A lot of the time, security is looked at as an IT problem. As soon as you can get outside of that, and stop thinking of it as a global aspect for your organization or your business and also incorporate your clients, then that’s when the real meaty conversation starts. That’s where you can start to really build on what you actually have. When it comes to do you do this, you’re like, yes, we’ve been doing this for this long. This is what we’ve been doing, this is how we’ve been tackling it, or we’re not doing it right now, but here’s all the work that we’ve been doing to lead up to what we’re going to do. It just creates that understanding and that awareness. If I can just get anyone to just be like, maybe I shouldn’t do this, I think I’ve won like that. That’s the the main aspect. I just want that little, you know, angel to pop up on their shoulder and be like, “Hey, wait a second. Maybe that’s not such a good idea. Let’s chat about it first.”


Britt Erler

Now, you both have clearly made so many significant changes in your organization that have been incredible for moving the business forward. I’m going to guess that it hasn’t all been rainbows and butterflies, there’s been a lot of challenges, right? A lot of things that maybe you did wrong, that you wish you would have known a little differently in the past. What are some of—I hate to say—but what are some of the worst decisions that both of you have ever made?


Neil Nickolaisen

My first bad decision was waiting five months to bring Amy on board with me, then I had to recover from that. I think, personally, I did a poor job of being empathetic to the situation, not of the company, but to the people in the company. This was a pretty dramatic change for them. The need for the change, changes we made were obvious to me, but maybe not obvious to them. I didn’t walk enough in their shoes. I think we could have accelerated some of the cultural changes and even some of the process changes if I’d been, if I’d understood better, what that their baseline and where they were coming from and their perspective. They really were coming from us perspective where what we were talking about was a necessary evil, but it was evil and therefore to be avoided, if possible. I just think we could have made the cultural and attitudinal changes faster if I’d have approached it differently.


Amy Knapp

I was really excited to hear Neil admitted some decision that he made poorly. Now that I’m thinking about it, I think one of the aspects is exactly that it’s especially coming into a legacy company with a lot of people who have a retention average of 14 years, and people who this has been their only job. A lot of, what I would say with the impacts to bad decisions was just the way that I reacted to some people’s viewpoint on change. It seemed like people would come to the table and just be absolutely adamant that they didn’t want to change anything at all and thinking it was just them. A big change that I made was deciding to try to understand where those people are coming from, because they don’t come to work to just obstruct everything. There’s a reason why they’re resistant. There’s a reason why they, if anybody mentions ISO, that they just, you know, raise two fingers and run away and hiss at you, that there’s that there’s history there and there’s detail as to why. Truly wanting to understand that actually helped me not make more worse decisions than I could have based on those people. Sometimes, you would dismiss people for just being obstructive and difficult and you would try to work without them in the in the picture. That’s usually not the best way to do it even if it’s obstruction hearing, you keep feeling like you’re hitting your head against the wall. It’s being inclusionary of those people as well, and taking into account that their experiences and their background will help you be able to move forward with what you’re trying to do. It’s a continuous decision that I have to make to not make the worst decisions of dismissing certain people who are resistant. I think that’s something that I just have to keep in mind all the time to help me explain what’s happening and get people to buy in, because it’s those people that as soon as you win, make things usually more successful.


Britt Erler

I think all executives could relate to that. A we wrap up this conversation today, I’ll go back to the positive aspects. Thank you for sharing those, it’s important because a lot of executives do make mistakes, and when they do own up to it, and that’s how they improve, and that’s how their employees improve as well. Thank you for sharing and wrap up today for both of you. As you look back at all of these significant changes that you made, what were the most important?


Amy Knapp

For me, I’m just gonna steal the limelight from Neil for once, it was bringing the IT organization onto a single toolset very early on. It was siloed, no one was really talking to each other tickets would go into the ether, and no one would know where they were. Being able to bring that into one platform and have everybody work in the same processes. We started with change management, and we brought incident problem in, and kind of evolved that from there. That platform has become something that is utilized within multiple areas of the organization. There’s about 80 projects that have been launched within that toolset in the last two years. Seeing that true integration, and also just that aspect of being able to track and know where things are and have things like safety catches logged in it and injury reporting and things like that, which are outside the norm for IT. Seeing that expand has been one of the best things that I put in place.


Neil Nickolaisen

I agree. And in addition to that, I would say this analogy that we already talked about, what is the role of information security, the team? Are they to find others’ mistakes, are they to help people proactively avoid ever making a mistake? I just think that that we had an analogy, we’re really good at Lean Manufacturing. People understood that you don’t have people doing QA on what you just produced, you’re responsible for the quality of what you just produced. Same with software. We just apply that information security data privacy is that this team is here to help never make a mistake. Never create an error. Never do something you’ll regret later. Let us help you get to that point in your life. It changed the relationship, like Amy said, so that people hear that, I’m from the government, I’m here to help. I’m from embrace security, I’m here to help. No, people really wanted to be helped. It changed the I’m going to monitor your work and I’m going to tell you when you mess up. No, that’s not what this team does. This team helps you avoid problems, helps you avoid mistakes. I think that’s really, culturally, what sort of turned the corner for us. To be honest, it took a while to get there because the relationship was in a bit of a hole.


Britt Erler

Amy, Neil, it’s been an absolute pleasure. You’ve provided so many insights that are going to help executives and companies move forward with their businesses in this new ever-evolving world that we’re in. Thank you so much for being here, and thank you to everyone who has joined us today as well. I’m sure you will all have further questions for Amy and Neil. Not to worry—there will be a discussion forum underneath this presentation. Thank you again for joining us and enjoy the rest of the CIO Visions Leadership Virtual Summit.


Neil Nickolaisen

Thank you.


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