OECD DIGITAL GOVERNMENT POLICY FRAMEWORK AND APPLICABILITY TO VIET NAM

  1. OECD Digital Government Policy Framework

Digital technologies and digital data in building economic and social resilience through strategic, agile, and innovative government approaches is a central issue with particular emphasis in the context of the COVID-19 pandemic. Digital technologies and digital data have played a vital role in managing the crisis and supporting societies and economies in countries with strong digital government foundations, especially in the context of declining levels of public trust in state agencies, an increasingly complex environment, budget constraints, a higher level of awareness of corruption, the capacity gaps in the civil service, and the increasing levels of inequality.

The COVID-19 pandemic and multi-dimensional crisis have disrupted most countries around the world; however, they also provide an opportunity to revisit strategic approaches on the use of digital tools and data to improve the delivery of public value.

One of the solutions to the current problems is to develop a digital government policy framework. Digital government is understood as “the use of digital technologies, as an integrated part of governments’ modernization strategies, to create public value” (Vo Manh Linh). Digital government is formed on the foundation of a digital government ecosystem including state agencies, NGOs, businesses, citizen organizations/associations, and individuals supporting the processes of developing and accessing data, services, and contents through interactions with the government.

From practice, the OECD Council on Digital Government Strategies has developed a Digital Government Policy Framework (DGPF), consisting of 6 dimensions (OECD, 2020) :

  1. Digital by design
  2. Data-driven
  3. Government as a platform
  4. Open by default
  5. User-driven
  6. Proactiveness

The DGPF is a policy instrument that helps governments identify key determinants for effective design and implementation of strategic approaches for the transition towards digital maturity of their public sectors. The DGPF supports qualitative and quantitative OECD assessments in collaboration with countries around the world, identifies the methodological framework, and designs the OECD Digital Government Index (DGI) – an index measuring the level of countries’ digital government maturity across the six dimensions.

Firstly, digital by design

A government that is digital by design has clear organizational leadership, paired with effective coordination and enforcement mechanisms where “digital” is not just seen as a technical issue, but also a required transformation enabler in all policy processes.

Secondly, data-driven

The digital age has magnified the importance of data as a fundamental element of digital governments. Data helps public sector organizations work together to forecast demands and understand how to respond to change and shape service delivery. In recent years, the exponential growth of data combined with the widespread use of mobile devices and the rapid development of emerging technologies have shown great potential to improve the internal operations of public sector organizations and their approaches to policy and service design. A data-driven public sector recognizes and takes steps to govern data as an important strategic asset in generating public value. Data is used in policy planning, delivering and monitoring, and is reliably and securely reused based on data ethical principles and rules. Based on previous studies on the role of data in society and the economy and reports on the path to becoming a data-driven public sector, the OECD has proposed a “data-driven government” model for governments to maximize the opportunities provided in the 21st century. According to the model, a truly data-driven government can:

  • Acknowledge and manage data as an important strategic asset; determine the value and measure the impact of data; and actively remove barriers to managing, sharing and reusing data;
  • Apply data to transform the design, delivery, and monitoring of public policies and services;
  • Understand the data rights of citizens in terms of ethical practices, transparency of usage, protection of data privacy, and security of data.

       A data-driven government will apply data to create public value through three types of activities: forecasting and planning; delivery; assessment and monitoring.

Thirdly, government as a platform

Governments take advantage of data, the Internet, and digital technologies to redesign services to focus on citizens’ needs. The scope and complexity of the public sector can lead to the risk that digital transformation in public services may happen in a piecemeal fashion over an extended period, making it difficult to achieve the goal of delivering public services in a timely manner, consistently, and effectively. Instead of approaching the transformation on a service-by-service basis, it is necessary to build the government as a platform to enable large-scale digital transformation by building an ecosystem that allows service groups to focus on unique users’ needs and focusing on providing basic services. This approach lays the foundations for building government as a platform, promoting the participation of non-state actors, and rethinking the relationship between citizens and the state. The government acts as a platform to meet user needs by providing clear and transparent sources of guidance, tools, data, and software that equip teams to deliver user-driven, consistent, seamless, integrated, proactive, and interdisciplinary services. The origin of the phrase “government as a platform” comes from the desire to transform the structures of government as a foundation for realizing the potential of “Government 2.0″.

Fourthly, open by default

Building on the core principles of digital government, the principle of open by default emphasizes the government’s proactive use of digital technologies and data to make public sector organizations more responsive, responsible and agile, providing more inclusive service. A digital government that is “open by default” when it shifts from top-down, centralized, and closed decision-making processes, based on the “black box” policy, to a more proactive approach, towards organizational efficiency, focusing on openness, cooperation, collective intelligence, and innovation. A digital government is open by default when it collaboratively uses digital tools and data to proactively engage with stakeholders and place collective intelligence at the heart of the dynamic and interactive process of public sector intelligence creation. The “open by default” digital government helps public policies and services more accessible, and facilitates non-state individuals participating in government decision-making and bringing new perspectives to policy life and public service delivery cycles, thereby promoting public democracy. In short, with the principle of “open by default”, the government will make government data and policy-making processes available for the public to engage with, within the limits of existing legislation and in balance with the national interest.

Fifthly, user-driven

Digital technology has changed the way in which citizens interact with each other and their government. A user-driven approach builds on integrating digital technology and data into the design and delivery of services and the shaping of public policy outcomes. Public modernization initiatives promote the value of technology and digital data, innovate interactions with the private and third sectors, or crowdsource ideas from within the administration and society, paving the way for the government to improve its effectiveness and efficiency. The user-driven approach is based on a few key factors: engagement by default; learning; accessibility and inclusion; talent and leadership; service design and delivery; interconnection.

Finally, the proactiveness

The digital age has made users expect convenient, timely, and fast services. This is especially true for the user experiences gained from Google, Apple, Facebook, Amazon – the companies that dominate the digital market and have familiarized the world with easily accessible services. A proactive government handles citizens’ requests and provides answers or solutions to their needs through the adoption of a push and pull delivery model. Proactiveness demonstrates the ability of the government and civil servants to forecast people’s demands and quickly respond to them so that citizens do not have to spend time providing data and performing cumbersome procedures. Besides, being proactive is also a means to improve public trust.

  1. Applying OECD digital government policy framework to analyze digital government deployment in Viet Nam

The six dimensions outlined in the OECD digital government policy Framework represent the most important axes in a digital government building and are used as a set of indicators to measure digital government maturity. When comparing with the six OECD digital government maturity assessment criteria, Viet Nam has achieved remarkable results.

2.1. Applying digital by design

To promote the development of e-government in Viet Nam in the new period, on April 21, 2015, the Ministry of Information and Communications issued Document No. 1178/BTTTT-THH promulgating the. e-government architecture of Viet Nam (Version 1.0) with the following main purposes:

  • Identifying and unifying the National e-government Architecture. This is the basis for state agencies at all levels to determine their responsibilities and positions in the country’s synchronous e-government development.
  • Serving as a basis for ministries, ministerial-level agencies, Governmental agencies, provinces, and centrally-run cities to build a detailed e-government Architecture to save time and resources, and at the same time ensure unity and synchronicity.
  • Based on the Viet Nam e-government Architecture Framework and the detailed e-government Architecture of the ministries, agencies, and localities, state agencies develop and implement the Information Technology (IT) application plan according to the roadmap and implementation responsibilities at all levels, ensuring the connection, communication, sharing, and reuse of information and information infrastructure.

In the context that new technologies of the Fourth Industrial Revolution developed rapidly and countries around the world are applying powerful new technologies to develop e-government, the Viet Nam e-government Architecture Framework has been updated in line with the trend. Following the direction of the Government, the Ministry of Information and Communications has issued the Viet Nam e-government Architecture Framework, version 2.0 (at Decision No. 2323/QD-BTTTT dated December 31, 2019) to instruct ministries, ministerial-level agencies, agencies attached to the Government, People’s Committees of provinces and centrally-run cities in developing e-government Architecture; to form and implement the synchronous application of the e-government Architecture system from the central to local levels.

2.2. Data-driven

Developing e-government based on platforms is an inevitable trend in the world, helping to save a lot of time and resources for implementation. By 2020, the most important foundations for the e-government development in Viet Nam have been formed and initially brought into play.

2.2.1. Specialized data transmission network of the Party and State agencies

Developing specialized data transmission network of the Party and State agencies (TSLCD Network):

  • In 2019: 100% of ministries, agencies, provinces, and centrally-run cities; 93.4% of distrICT and towns are connected to the TSLCD network;
  • In 2020: 100% of ministries, agencies, provinces, and centrally-run cities; 98% of counties, distrICT, and towns are connected to the TSLCD network (Tien Hung, 2021).

2.2.2. Database

The database is an important resource to develop e-government towards the digital government, digital economy, and digital society. Over the past time, many databases have been formed and initially brought into play. By 2020, the current status of database development is as follows (Nguyen Cong Minh, 2020; Quang Vu, 2021) :

Some databases for e-government platforms have been built:

  • The insurance database manages information about 24 million households participating in health insurance, including information on more than 90 million people with health insurance cards;
  • The national electronic civil status database is formed and synchronized in the provinces and centrally-run cities, with over 12 million birth registration data;
  • National enterprise registration database containing real-time business registration information of more than 1 million enterprises and affiliated units; 100% of business registration files are digitalized;
  • The financial database contains tax management information of about 65 million individuals and over 700,000 businesses;
  • The education database contains information from more than 53,000 schools; 1.5 million teachers; 23 million student records;
  • Common database of the Ministry of Health includes 10,000 drugs and 41,000 pharmaceutical business establishments.

The implementation of many other key national databases is being accelerated, such as the national residence database; National Land Database.

2.2.3. Data sharing and Integrated platforms

Integrated platforms for sharing data play a central role in connecting and sharing data among state agencies. By the end of 2020, a system of data sharing and integrated platforms has been formed on a national scale according to the Viet Nam e-government Architecture Framework. The current status of platform development is as follows:

  • National data sharing and integrated platform: The platform has connected with all integrated platforms, data sharing of ministries, sectors, and localities, forming a connection and data sharing environment on a nationwide scale. The platform has supported the connection and sharing of connected data with more than 200 information systems of more than 85 ministries, sectors, localities, and businesses; connected to five national databases, seven information systems from central to local levels. From 2019 to now, there have been more than 12 million transactions made through the National Data Sharing and Integrated Platform (Pham Trung, 2021).
  • The Data sharing and Integrated platforms at the ministry/province level have been developed rapidly, meeting the needs of connecting and sharing data within ministries and provinces and connecting externally. Specifically (Gia Huy, 2021a) :

+ In 2018: 03 ministries, agencies, and localities have local government service platform (LGSP), reaching the rate of 3.2 %;

+ In 2019: 04 ministries, ministerial-level agencies, governmental agencies, 21 provinces/centrally-run cities have LGSP, reaching the rate of 27.17%;

+ In 2020: 100% of ministries, ministerial-level agencies, provinces, and centrally-run cities have LGSP and are connected to the national data sharing and integration Platform.

2.2.4. National data portal

The national data portal (data.gov.vn) was launched in August 2020 to promote open data of state agencies and develop digital services for digital socio-economic transformation. Over 10,000 open datasets across 12 domains have been published on the Portal.

2.3. Government as a platform

Recognizing the important role of the Government in the process of building and developing digital government towards digital transformation, the Party and State have issued a lot of detailed, specific, and clear foundation documents to facilitate the participation of agencies, businesses, and people in the reform and transformation process. The Government and the Prime Minister have paid close attention to and directed the e-government. Since August 2019, the Resolutions of the Government’s regular sessions have issued key documents on digital transformation and digital government development.

  • On September 27, 2019, the Politburo issued Resolution No. 52-NQ/TW on guidelines and policies on active participation in the Fourth Industrial Revolution;
  • On April 17, 2020, the Government issued Resolution No. 50/NQ-CP on the Government’s Action Program on implementation of the Politburo’s Resolution No. 52-NQ/TW of September 27, 2019 on guidelines on active participation in the Fourth Industrial Revolution;
  • On June 3, 2020, the Prime Minister issued Decision No. 749/QD-TTG approving the “Program for national digital transformation by2025, with orientation to 2030″;
  • On June 15, 2021, the Prime Minister issued Decision No. 942/QD-TTG approving the “Strategy for e-government development towards digital government for the 2021 – 2025 period, with orientation to 2030″.
  • On March 7, 2019, the Government issued Resolution No. 17/NQ-CP on key tasks and solutions for the e-government development in the 2019-2020 period, with orientation to 2025;
  • On August 28, 2018, the Prime Minister issued Decision No. 1072/QD-TTG on the establishment of the National Committee on e-government, headed by the Prime Minister, which will directly direct the e-government building and development.
  • On May 26, 2020, the Prime Minister, Chairman of the National Committee on e-government, issued Decision No. 701/QD-TTG consolidating the National Committee on e-government; Accordingly, the National Committee on e-government is allowed to expand its functions and tasks to direct more content on digital transformation, digital economy, and smart cities.
  • On October 21, 2020, the Prime Minister promulgated the Regulation on the operation of the National Committee on e-government in Decision No. 414/QD-UBQGCPĐT;

Ministries, agencies, and localities actively participate in directing and administering e-government development; setting up steering committees for e-government development; expanding the functions and tasks of the Steering Committee for the development of e-government.

  • On June 29, 2020, the Ministry of Information and Communications issued Official Letter No. 2390/BTTTT-THH guiding the Digital Transformation Program Framework of ministries, agencies, and localities.

The Ministry of Information and Communications, Viet Nam Social Security, and many provinces and cities have consolidated the Steering Committee on building e-government according to the Prime Minister’s Decision No. 701/QD-TTG dated May 26, 2020, to guide more content on digital transformation, digital economy and smart cities. These provinces and cities include Ben Tre, Cao Bang, Gia Lai, Kon Tum, Dak Lak, Ha Nam, Ninh Thuan, Thua Thien Hue, Lang Son, Long An province, Quang Tri, Bac Giang, Khanh Hoa, Tay Ninh, Quang Ngai, Dong Nai, Tay Ninh, Quang Ngai, Dong Nai, Hai Phong, Ninh Binh, Thanh Hoa, Vinh Phuc, Bac Ninh, Bac Lieu, Lam Dong. The Ministry of Information and Communications and specialized IT units of ministries, agencies, and localities have promoted their roles as focal points, actively organizing the implementation of e-government at all levels.

  • Open by default

The Ministry of Information and Communications has directed and promoted the Vietnamese technology business community to build e-government development platforms and implement national digital transformation. In recent years, the Ministry of Information and Communications has introduced and launched an important platform every week. As of December 2020, nearly 40 platforms have been introduced and launched (Viet Nga, 2021) : online teaching and learning management platforms of Viettel, VNPT; remote medical examination and treatment consulting support platform supported by Viettel; VOV Bacsi24 online health consultation platform; Vpostcode postal code platform; online conferencing platform Zavi; Vietnamese cloud computing platform by Vietnamese enterprises (VNG, Viettel, CMC, VCCorp); Comeet online conferencing platform; the overall business management platform 1Office; VAIS voice-to-text converting platform; platform for providing services of the Safety and Security Operations Center (SOC) to meet the needs for connecting and information sharing; PayGov national payment gateway; Stringee communication platform as a comprehensive communication solution; blockchain technology platform akaChain developed by FPT Joint Stock Company; platform using artificial intelligence for Vietnamese people; applying artificial intelligence (AI) technology to be able to understand the content that customers want to convey in the communication process and automatically improve the system continuously from real situations; application platform of the latest digital technologies to unify all education management operations on one system; VNPT eKYC electronic identification platform; FPT.AI platform; akaBot platform; management platform Base.vn; Flex Digital Government development platform; ezCloud Tourism Business and Governance platform; Data Mining platform; Unified Corporate Governance platform.

In addition, many information systems have been implemented and achieved the following results:

  • Document for management and administration:

+ The rate of electronic documents exchanged between state agencies increases every year. Specifically, the rate of e-document exchanges nationwide over the years is as follows: 2018: 72%; In 2019: 86.5 %; In 2020: 90.81% (exceeding the target of 90% by 2020) (Anh Tuan, 2021).

+ The National Enterprise Service Bus has connected to send and receive electronic documents at 02 levels of government with 94/94 ministries, agencies, and localities (100%) and the Party Central Committee Office, the Institute Supreme People’s Procuracy, Supreme People’s Court, National Financial Supervision Committee, socio-political organizations (Viet Nam Fatherland Front, Viet Nam General Confederation of Labor, Central Ho Chi Minh Communist Youth Union, Viet Nam Women’s Union, Viet Nam Veterans Association). On March 12, 2019, the Prime Minister inaugurated the service system, and until March 8, 2021, there were more than 4.5 million electronic documents sent and received via the National Enterprise Service Bus; the number of e-documents sent and received in 2020 is 2.5 times higher than that in 2019 (People’s Daily, 2021).

  • A reporting system to monitor and summarize the performance of tasks of state agencies at all levels. On August 19, 2020, the National Reporting System, the Center for Information, Direction and Administration of the Government and the Prime Minister was launched. This is a smart digital infrastructure for leadership and governance based on digital data in accordance with the national digital transformation roadmap. Up to now, the system has connected with the reporting system of 14 ministries, agencies, and 37 localities. Online interaction and administration through the data network system of the Ministry of Defense, specialized network, the Internet with nearly 57 units in ministries, agencies, and localities; connected 32 cameras to monitor hydroelectric dams; provided data on 105/200 socio-economic indexes for the direction and administration of the Government and the Prime Minister; provided online data for 8 monthly socio-economic indexes (Gia Huy, 2021b).

            Information system for meetings: All ministries, agencies, and localities have implemented online meetings to save time and costs; this has been especially effective during the Covid-19 pandemic. To promote IT application in facilitating meetings and handling government affairs, the e-Cabinet system has connected to 22 ministries and ministerial-level agencies, helping to synchronously and comprehensively manage meetings of the Government, organize the collection of opinions of the government members in a simple, fast and effective manner on the network environment, reducing time and saving costs.

            Electronic one-stop shop: Most ministries, agencies, and localities have implemented the electronic one-stop shop to computerize the reception and process of administrative dossiers, which increases productivity, publicity, and transparency of activities of state agencies.

  • User-driven

E-government and digital government place their central focus on users. Viet Nam has achieved many results in providing public services to people and businesses. To be more specific:

            By the end of 2020, all ministries, agencies, and localities have launched public service portals to provide online public services. Public services promote easy access to public services, and save time and costs in carrying out administrative procedures.

More than 55% of public services have been provided online at levels 3 and 4. In 2020, thanks to a new and platform-based way of doing things, the rate of level 4 online public services increased sharply. The average rate of level 4 online public services nationwide over the years is as follows: 2016: 1.42%; 2017: 2.53%; 2018: 4.55%; 2019: 10.76%; 2020: 30.86% (exceeding the target of 30% by 2020) (Hai Thanh, 2021; Khanh Linh, 2021).

  • The National Public Service Portal was launched on December 9, 2019, and has provided citizens and businesses with a single point to access online public services of state agencies. From the launching date with the initial 8 public services to March 8, 2021, more than 2,800 public services have been integrated; nearly 6,700 administrative procedures have been provided at 4 levels of government, with more than 116 million visits, 467 thousand registered accounts; more than 42.5 million dossiers in a synchronic manner; over 930 thousand dossiers implemented online and more than 46 thousand electronic payment transactions made on the Portal; over 53 thousand calls, more than 10 thousand complaints and recommendations have been received and supported (Huy, 2021). Currently, the Government Office is urgently finalizing the draft Regulation on the management, operation, and exploitation of the National Public Service Portal based on appraisal opinions of the Ministry of Justice before submitting it to the Prime Minister for promulgation in March 2021.
    • Proactiveness

The work of ensuring safety and network security is strongly focused on in accordance with the development of e-government. In recent years, ministries, agencies, and localities have actively implemented information security assurance under the 4-layer model. As of December 2020, the total number of ministries, agencies, and localities that have implemented information security assurance under the 4-layer model is 83/83 units, reaching the rate of 100% (Van Anh, 2020). This rate was growing rapidly month by month in 2020.

To ensure network information security, the Ministry of Information and Communications has implemented monitoring and proactive scanning in Viet Nam’s cyberspace; evaluating, compiling statistics and promoting communication and warnings on the mass media to alert users. In 2020, the National Cyber Security Center under the Ministry of Information and Communications recorded 5,168 cyberattacks causing problems to information systems in Viet Nam, a decrease of 0.15% compared to 2019. Minh Son, 2020). To form a wide network, and continuously and timely monitor warnings about network safety and security, on November 29, 2019, the Ministry of Information and Communications launched the System for Information Sharing and Security for e-government.

Although there are still many difficulties and obstacles in the process of building and developing e-government towards the digital government, the initial results have shown a determination of the Party and State of Viet Nam, trying to make the country quickly affirm its position in the process of building and developing digital government with countries around the world and achieve the set goals: Viet Nam has the e-government development and digital government indexes at a high level in the world, in the top 30 countries ranked by the United Nations; digital government will transform the way to serve people and businesses, reduce costs, increase business productivity, create favourable conditions, bring people’s satisfaction, encourage people’s and businesses’ participation in activities of state agencies to jointly create values, benefits, satisfaction, trust, and social consensus; the digital government transforms the way it organizes and operates the working environment and working tools so that cadres, civil servants, and public employees can best perform their duties.

References

  1. Van Anh (2020). 100% of ministries, branches, and localities have ensured information security according to the 4-layer model, 2021, from the link: https://ictnews.Viet Namnet.vn/bao-mat/100-bo-nganh-dia-phuong-da-bao-dam-attt-theo-mo-hinh-4-lop-273347.html
  2. Nhan Dan Newspaper (2021). More than 4.5 million electronic documents sent and received through the National Document Communication Axis.
  3. Gia Huy (2021a). The digital government in Viet Nam will be formed in 2025, 2021, from the link: https://vpcp.chinhphu.vn/chinh-phu-so-tai-viet-nam-se-duoc-hinh-thanh-vao-nam-2025-11525658.htm
  4. Gia Huy (2021b). E-government contributes to improving service quality for people and businesses, 2021, from the link: https://baochinhphu.vn/chinh-phu-dien-tu-gop-phan-nang-cao-chat-luong-phuc-vu-nguoi-dan-dn-102288853.htm
  5. Tien Hung (2021). A bright spot in the development of e-government, towards the digital government.
  6. Khanh Linh (2021). The rate of online public services at level 4 nationwide only reached 37.43%.
  7. Vo Manh Linh The relationship between “E-government” and “Digital Government” – Part 1, 2021], from the link: http://cchc.mard.gov.vn/Pages/moi-lien-he-giua-chinh-phu-dien-tu-va-chinh-phu-so–phan-1.aspx
  8. Nguyen Cong Minh (2020), Status of data sharing in IT infrastructure and application activities in Viet Nam, 2021, from the link: https://aita.gov.vn/thuc-trang-chia-se-du-lieu-trong-hoat-dong-ung-dung-va-ha-tang-cntt-o-viet-nam
  9. Viet Nga (2021). Let the Vietnamese technology platform dominate the “home field”, 2021], from the link: http://www.Ha Noimoi.com.vn/tin-tuc/Oto-xemay/997201/de-nen-tang-cong-nghe-viet-chiem-linh-san-nha
  10. OECD (2020). The OECD Digital Government Policy Framework, 2021, from the link: https://www.oecd-library.org/governance/the-oecd-digital-government-policy-framework_f64fed2a-en
  11. Minh Son (2020). More than 5,000 cyber attacks on Viet Nam in 2020, 2021, from the link: http://www.Ha Noimoi.com.vn/tin-tuc/Oto-xemay/987026/hon-5000-cuoc-tan-cong-mang-vao-viet-nam-trong-nam-2020
  12. Hai Thanh (2021). In the period 2021-2025, the information and communication industry accelerates digital transformation. Access from the link: https://binhphuoc.gov.vn/en/news/Hoat-dong-tinh-dao-tinh/giai-doan-2021-2025-nganh-thong-tin-va-truyen-thong-day-manh-tang- toc-chuyen-doi-24000.html
  13. Pham Trung (2021). National Data Integration and Sharing: “Backbone” Platform, 2021], from the link: https://nhandan.vn/thong-tin-so/tich-hop-chia-se-du-lieu-quoc-gia-nen-tang-xuong-song-643140/
  14. Anh Tuan (2021). Minister of Information and Communications Nguyen Manh Hung: The percentage of electronic documents exchanged online from 72% in 2018 to 86.5% in 2019, 2021], from the link: https://viettimes.vn/bo-truong-bo-tt-tt-nguyen-manh-hung-ty-le-van-ban-dien-tu-duoc-trao-doi-qua-mang-tu-72- men-2018-len-86-5-men-2019-post124058.html

Assoc.Prof.Dr. Luu Kiem Thanh

Former Deputy Director of the National Academy of Public Administration

MSc. Pham Huyen Trang

National Academy of Public Administration

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