Loading...

Follow QCS International Blog on Feedspot

Continue with Google
Continue with Facebook
or

Valid

With ISO 45001 (Health and Safety) now also following the structure of ISO 9001 (Quality) and ISO 14001 (Environment), there has never been a better time for considering integration of your management systems. Our experience shows that gaining certification for two or more standards is never twice the effort!

With the new common framework for management system standards (Annex SL) now in place across a suite of ISO documentation it is easy to see the overlap, common requirements and duplication within each. Simply, you can combine items such as document control, management of nonconformance, internal audits and management review etc. Other elements such as context, understanding the needs of interested parties and risk management can all be easily integrated together.

When working with our clients we always set up systems that have the potential to be integrated – even if you are not seeking certification to a second standard at the time of our help. So, even if all you need for now is ISO 9001, consider that what you develop now can also, then be the framework for ISO 14001 etc. It will save a great deal of effort in the future.

Also, to consider only quality without also thinking about how you may impact on the environment or generate health and safety hazards means you are failing to appreciate the outcome of decisions made.

For example, you may develop a new product:

  • To help deliver what your clients want and need (meeting quality objectives).
  • But, there is always the risk of this generating environmental impact (think about the raw materials consumed or energy used).
  • Or the introduction of health and safety hazards (is the task of manufacture hazardous?).

Integration encourages you to think about the whole picture.

With more standards now adopting the common framework (the latest being ISO 50001 for energy management) then the attraction of integration grows. If you think it is something you might benefit from then do give us a call.

Auditing is core to all standards and QCS offers specialist, bespoke training on integrated management system auditing. Auditors with a wider understanding of processes usually generate better and more useful reports; the basis for driving improvement. This training is tailored to clients’ requirements and includes a live audit within your place of work.

You can find out more about our IMS auditing training at https://www.qcsl.co.uk/integrated-auditing-courses/

The post Integrated Management Systems appeared first on QCS International.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

Theresa May’s recent heralding of Artificial Intelligence in Healthcare as a potential focus for UK research and development provides an opportunity to define our regulatory expectations for this tech.

“The development of smart technologies to analyse great quantities of data quickly and with a higher degree of accuracy than is possible by human beings opens up a whole new field of medical research and gives us a new weapon in our armoury in the fight against disease. “ – Theresa May.

Treatment options based on available clinical data has always been firmly in the realm of clinician responsibility, determined by the competency and expertise they have gained through years of training and experience.
Any AI would have to demonstrate that the clinical outcome from the technology was superior to the current state of the art (a properly qualified medical professional) and that the benefits of the technology outweigh the additional risk introduced.

The algorithms employed to decide on treatment would require to be validated to ensure the results they produced were in line with clinical expectations. This could prove difficult if the advice is at odds with accepted clinical practice, whilst being specific to the patient based on genetic and environmental factors. The clinical investigation of these products would then need to be sufficiently statistically powered to the required confidence levels, which means large number of trial volunteers and ultimately money to pay for this.

The new in vitro diagnostic device regulations make it clear that software performing these functions is classed as a medical device and as such the worlds of Big Data and device regulations will be required to work together to develop a robust framework for regulatory approval.

The post Artificial Intelligence in Healthcare. appeared first on QCS International.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 
It is not just large organisations that face the risk of attacks on their information technology systems.  Small organisations are also targeted by criminals as they frequently have less elaborate defences or, in some cases have done very little to prepare themselves for any kind of attack.

In 2018 there was a big rise in smaller companies being targeted and that trend is continuing to rise in 2019.

  • Cyber-attacks cause:
  • Financial damage – costs that you cannot get back or sometimes cannot insure against
  • Damaged reputation – bad news about your organisation makes potential clients more cautious about using your services/products
  • Computer downtime – reducing efficiency and productivity
  • Temporary closure of services or product runs – resulting in you losing business or failing to meet deadlines
Doing nothing to prepare for possible cyber criminality is not an option.
Somethings are simple to do, just ensuring your staff change their passwords frequently for example but other actions require a more thorough approach.  To make your response effective you might think about the following:
  • Where are your key vulnerabilities?
  • What back-up systems do you have in place in case of a loss of data?
  • Do you rely on cloud-based systems or your own server?
  • What assets do you have, how are they used? (include computers, laptops, mobile phones)
  • Have your policies in place for accessing the internet, setting up and changing passwords, email use?
  • Do you limit access to compartments of your data only – or can everyone see everything?
  • Do you ever let external agencies or individuals have access to your systems?
If you are unsure of the answers to the above, or if these questions suddenly make you realise that you have no or very little controls in place then perhaps a review of arrangements is a priority for your organisation.  This becomes doubly important if data handling and protection is something your clients expect you to undertake securely.

There are no quick fixes to addressing any issues you have – and don’t believe anyone who says there are.  One improvement option is to use the international standard for information security – ISO 27001.  Like other standards it requires, as a first step, a review of current arrangements and the identification of vulnerabilities.  The standard then sets out key controls that you need to demonstrate are in place.

If ISO 27001 is something you want to find out more about then just get in touch with QCS International and we can explain what training and consultancy services we can offer.

Please don’t become a victim of cyber security crime.  Take the time to explore the avenues of vulnerability and take the first steps to combat the possibility of security breaches.  The cost of doing nothing can be considerable.

The post How Safe is your Company from Cyber-Attacks? appeared first on QCS International.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

ISO 45001, the new international standard for health and safety management, has now been live for 12 months.  Following the same structure as other management system standards such as ISO 9001 and ISO 14001, the new benchmark for health and safety delivery is slowly but surely replacing the old British standard OHSAS 18001.

If you already have ISO 9001/ISO 14001 then the introduction of the new ISO 45001 should not be arduous.  Much of what is in the standard (in comparison to OHSAS 18001) reflects the need for risk-based management, context, interested parties and worker participation.   None of these should create a barrier to the introduction of the new requirements.

ISO 45001 does not require ‘transition’ from OHSAS 18001.  It is not an update, but a completely new standard.  Most certification bodies have taken the view that if you have OHSAS 18001 then the leap to ISO 45001 is not too great to require a stage one and stage two certification visit – instead they offer ‘migration’ across to the standard.  Simply, you need to ensure your OHSAS 18001 system is fully implemented and then adjust/add to this to meet any changes the ISO 45001 standard introduced.

Key changes include:

  • Greater emphasis on worker participation and consultation (including commitment to this within your health and safety policy)
  • Understanding the context of the organisation – what internal and external issues will affect the ability of the management system to work effectively (this should not be a problem for companies already covering this with ISO 9001)
  • New requirements to understand the needs/expectations of interested parties and workers

Note, what you DO NOT have to do includes:

  • Removal of the ‘management representative’ as described in OHSAS 18001 but not referred to is ISO 45001. Having a member of staff responsible for H&S management remains a requirement of the standard
  • Remove existing manuals, instructions etc. ISO 45001 (as other updated standards) have no mandatory manuals, procedures etc. But if you have some and they work well for you, then retain them!
  • Change current health and safety arrangements – the standard may have some new elements but the basics of understanding risk/hazard and implementing controls continues. It can offer an opportunity to review/refresh existing arrangements – but if they are not broke, don’t fix them!

QCS has consultants and trainers able to take you on the journey to ISO 45001 certification – whether you be migrating from OHSAS 18001 or installing a health and safety system for the first time. Our training offers introduction to the standard as well as auditor courses (and auditor migration for those previously only working within OHSAS 18001). We can also have a consultant work with you to ensure you develop and implement all that you need to achieve certification – something we guarantee to achieve first time (with your UKAS accredited certification body).  Contact us to find out what we can do and to receive a bespoke quote. Tel: 01236734447.

The post ISO 45001 – One year old! appeared first on QCS International.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

Where to start …

It is important to prove to your clients (both internal and external) that you are ‘secure’, compliant with all applicable legislation and can provide them of assurance in how you handle their sensitive information.

The management of information in your business can be achieved by following both the requirements set out in the ISO 27001 Information Security Management Systems standard itself, by considering specific risk(s) in your organisation and by adopting the controls it lists.

There is a requirement to consider the applicability of controls ranging from establishing policies to conducting information security reviews. Justification for inclusion of controls, or not, is to be stated.

We’re often asked, where do we begin?

Step 1 – By conducting a gap analysis an organisation can establish what is already in place and then include it in the system or adjust it where necessary to show conformance with ISO 27001. This is usually easier than trying to do everything from scratch.

The gap analysis shall suggest what procedures need to be changed/introduced, what controls are necessary for ISO 27001 certification, training needs for staff and the development of a system to review and check the effectiveness of controls introduced.

Consider:

  • how information is processed and stored, what procedures are in place and are they effective
  • review assets used to manage data – are physical controls suitable and is software and less tangible elements robust
  • check awareness amongst employees on their responsibility for information security – do they need training and do they need to have
  • clear instruction on their role
  • determine what actions to take to address gaps

It can be daunting to start the process, however, the cost of ignoring risk, no matter how small, can be considerable.

Planning starts with training so that employees fully understand what is required. The first place to start is with a day’s training to understand the application of ISO 27001. To have it broken down and explained by qualified ISO 27001 trainers and consultants and to let this lead you to understand if your organisation is fully compliant or not.

Information on all ISO 27001 IRCA registered courses can be found at www.qcsl.co.uk

The post Preparing for ISO 27001 appeared first on QCS International.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

ISO 13485 QMS requirements and FDA’s QSR to Merge.

Medical device companies need to be adept at negotiating different regional regulatory requirements. They have become accustomed to the complexities surrounding varying requirements and establishing processes to cope.

It had been suspected, given the changes introduced in the 2016 version of ISO 13485, that harmonisation with US requirements was at the front of the technical committees mind.

The new version of the standard shunned Annex SL, applied in the new version of ISO 9001:2015, in favour of the existing standard format.

FDA press officer Stephanie Caccomo is reported as stating: “With the publishing of the ISO13485:2016 revision, there has been industry evaluation of the regulatory requirement linkages to the standard. In the spirit of global harmonization of quality management systems, the FDA is considering an evaluation/mapping of the 13485 clauses to the appropriate U.S. regulatory requirements.”

This is a welcome development for the medical device industry, simplifying the requirements for quality management systems.

For once, things might get a little simpler.

The post Can’t We All Just Get Along? appeared first on QCS International.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 
OUT WITH THE OLD …………………… (OHSAS 18001:2007)
IN WITH THE NEW ………………….. (ISO 45001:2018) WHEN ?
  • 12th March 2018 – ISO 45001 was published
  • March 2021 – OHSAS 18001 will be withdrawn
  • Currently Certified to OHSAS 18001? – 3 years to migrate to ISO 45001
WHY?
  • ISO 45001 will follow common terminology and structure of Annex SL
  • Easily integrated with other management systems, such as ISO 9001 and ISO 14001
  • ISO 45001 enables organisations who trade internationally across geographic areas
  • ISO 45001 will be a truly international management standard
WHAT IS NEW ?
  • Organisations MUST consider what external risks exist
  • This means not only looking internally but at any impacts on the wider society
  • Annex SL will focus the organisation on Context, Role of Top Management and Employee contribution.
  • Health and Safety integrated into both organisational structure and additional management systems
  • Accountability for Health & Safety responsibilities will NOT be solely with the Health & Safety Manager but integrated into business operations.
BENEFITS
  • Clearer and improved requirements and clauses
  • Employee participation into core Health & Safety Management Systems
  • Simple integration into ISO 9001 (Quality), ISO 14001 (Environmental)
  • Top Management involvement
  • Organised risk management to reduce hazards and risks
  • “Context of Organisation”
  • Clear understanding of internal and external drivers
  • Clarity on company planning and objectives
  • Clear and unambiguous process for managing outsourcing of contractors for reduced risks
QCS Works with some of the first Scottish Companies to gain ISO 45001 on 12 March 2018

QCS International is proud to have worked with both companies to ensure implementation and integration of the new ISO 45001 International standard was a seamless process into their existing management systems

Congratulations to:

OKI and OPG OPG

QCS International have been working with OPG, one of Scotland’s leading suppliers of vehicle graphics solutions, for over 8 years. Health and safety concerns were always of paramount consideration to OPG, and QCS assisted in the development of health and safety management system to achieve OHSAS 18001.

Aiming to be at the forefront of new developments, OPG has sought to become one of the first companies in Scotland to achieve certification to ISO 45001. Given that certification bodies seek exemplar clients to assist in the development of their auditor skills, OPG was chosen to be a leader in ISO 45001 Certification Programme. We are pleased to have worked with them and very happy to see them awarded this certification on the day of its publication!

OKI

OKI UK Ltd in Scotland manufactures Original OKI Consumables used in OKI’s pioneering digital LED printers and MFPs for professional in-house printing and OKI’s robust dot matrix printers for multi-part forms and invoices.

QCS supports OKI UK; the company uses our services to ensure ongoing compliance for environmental regulations (ISO 14001) and for health and safety requirements.

The new ISO 45001 standard includes a requirement to commit to and to achieve all relevant compliance obligations and we are happy to have assisted OKI UK to achieve certification to the new standard on the day of its publication. 

QCS International Ltd

We are the experts to ensure you gain the full benefits that can be achieved through certification to management system standards. ISO 45001, as the first international standard for health and safety management, is the best way to have your organisations health and safety arrangements recognised here and throughout the world.

For companies with OHSAS 18001 QCS is able to offer a full migration service to ensure you meet the new, updated requirements that ISO 45001 contains. Our fixed-price service reviews your arrangements and then delivers a bespoke action plan to address any gaps or weaknesses in your current systems. Just call us today for a quotation.

If you are new to health and safety management systems, then the introduction of this new standard gives you a great opportunity to develop health and safety management arrangements now to gain early certification to the standard. There is great commercial and regulatory advantage to being one of the first to gain certification. QCS is able to assist you with consultancy support and training to meet the requirements of the standard.

Migration

If you are migrating from OHSAS 18001 to the new ISO 45001, QCS suggests that you are aware of the following changes, and avoid some obvious pitfalls:

  • Do not think what you already have is not fit for purpose! Much of OHSAS 18001 requirements have been adopted in ISO 45001 – so do hold on to much of what you already have (QCS can advise). Do not throw anything away!
  • If you have made transition to the new ISO 9001 or ISO 14001 then there is lots of commonality with ISO 45001. However, do not assume that they are completely identical!
  • If you have certification to ISO 9001 and/or ISO 14001 then the most obvious approach is to now have an integrated management systems. Combining elements of each reduces overall resource requirements
  • Do not leave things too late! With three years to complete transition you may think that there is nothing to worry about. Experience shows that this is dangerous and that the sooner you take action the better. Some companies are now struggling with completion of ISO 9001 transition this year, for example.

The post Launch of NEW ISO 45001:2018 appeared first on QCS International.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

As a Contact Centre, how can you ensure you are managing risk and are compliant with current legislation on data handling and protection?

Whatever services you provide, you hold complete responsibility for the data you receive, process, store and destroy. To fully demonstrate your commitment of good information security to stakeholders, and to deliver sector-leading, secure and efficient services, consideration should be given to achieving ISO 27001 certification. The award of this certification recognises your adoption and implementation of international best practice in information security.

Should your organisation already have ISO 9001 for quality management it is simple and easy to integrate ISO 27001 for Information Security in to your current arrangements (likewise, if you have ISO 27001, you can add ISO 9001 if this is not in place).

Core to the ISO 27001 approach is risk management; the identification of the risks your organisation faces, the adoption of suitable controls and ongoing checking on the effectiveness of these controls. The objective of such an approach is to deliver and demonstrate continued improvements in information security. The data and information assets you hold are liable to potential threats, both internally and externally. Managing the risk ensures that your organisation holds on to its reputation for safeguarding the information of your clients.

What are the features of ISO 27001?

  • Plan, Do, Check, Act (PDCA) Process Model – as with all management system standards
  • Process based approach – understanding how different elements of your organisation fit together and where these generate risk
  • Application of controls – to address the risks and to improve information security
  • Information Security and not just IT Security (the standard provides a framework for a wide range of controls)
  • Information Security to cover people, processes and technology
  • Certification is worldwide– and it provides your clients with assurance that you manage risk effectively

Step 1 – By conducting a gap analysis an organisation can establish what is already in place and then include it in the system, or to adjust it where necessary to show conformance with ISO 27001. This is usually easier than trying to do everything from scratch.

We find in our work that many organisations are already meeting many of the requirements within their own procedures and arrangements. A gap analysis measures these against the standard and makes recommendations on what must happen if certification is to be achieved. The output of such analysis tends to be an action list.

The gap analysis shall suggest what procedures need to be changed/introduced, what controls are necessary for ISO 27001 certification, training needs for staff and the development of a system to review and check the effectiveness of controls introduced.

The kinds of documentation and action required to lead you to conformance with the standard include:

  • Issuing and adoption of Information Security Policy
  • Establishment of key information security objectives and measures – to demonstrate improvement and to drive change
  • Review and adoption of effective procedures for HR, IT systems, Admin, Finance and Software
  • Understanding your assets, and how these are to be managed
  • Adoption of applicable controls as described within ISO 27001
  • Risk Assessment procedures
  • Audits, inspections and reviews on the effectiveness of arrangements
  • Management Reviews – making decisions on changes and improvements

It can be daunting to start the process, however, the cost of ignoring the risks to your information security systems, no matter how small, can be considerable. QCS International can help you to understand the process and ensure you have the necessary skills to manage the system yourselves.

What are the benefits of ISO 27001?

  • You systematically identify and manage all your information security risks
  • You have systems in place to help deliver compliance with legislation, such as GDPR
  • You have recognised certification, providing assurances to your clients
  • You can market the strength and reliability of your systems
  • Be the best you can be in your industry

Perhaps the first place to start is with training to understand the structure and key requirements of ISO 27001. This will help you see where you are and where you need to go.

The post The Steps to ISO 27001 Compliance in Contact Centres appeared first on QCS International.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

Many law firms are already registered to ISO 9001 for their Quality Management Systems and seeing the benefits of a solid, process-based system across their business. Increasingly as firms handle sensitive data on behalf of clients many legal practices are seriously considering a framework to control their risk, compliance and governance in relation to Information Security.

ISO 27001 is the International Standard for Information Security and after several high-profile data breaches coming from blue chip organisations, social media outlets and the legal profession, it may be that the time is right for you to investigate the benefits of an International standard to manage the risks to the data you hold.

Law firms actively manage and comply with Data Protection and GDPR and often defend those organisations found to be in breach of the regulations and legislation. To identify, consolidate and manage risks associated with Information Security within their own practices would certainly demonstrate commitment to client’s data confidentiality. Achieving Certification to ISO 27001 would demonstrate such a commitment.

What are the benefits for your law firm?

  • A management system to ensure management of Information Security risks,
  • Compliance with legislation including GDPR,
  • Internationally recognised certification,
  • Marketing benefits through the provision of assurance to your clients.

Within a law firm the most valuable asset is information: how you store it, use it, retain it, share it and archive it ALL within a secure system. Using a systematic and process-led approach allows you to protect information from risks and threats – this can only be done by firstly identifying ALL risks and threats to your clients and your business and then applying suitable controls. ISO 27001 provides the framework in which this can be achieved.

Fraud, cyber-attacks, data leaks and information access are big business for fraudsters and you only need to read the daily newspapers to see how this is affecting banks, insurance providers, social media, legal profession and many ordinary citizens. Certification helps firms demonstrate to their clients how their firm:

  • Protects their clients and reputation
  • Ensures secure exchanges of information
  • Avoids financial penalties
  • Meets the needs of partners and stakeholders
  • Achieves international regulatory compliance

A vast number of organisations in the UK already have robust Information Security systems and many are already certified to ISO 27001. It is now unsurprising, therefore, that they would expect their lawyers and counsel to demonstrate the same standards in securing data they have already in place.

Many calls to QCS have the following questions on information and date security.

  • How do we prove to our clients that their data is secure?
  • What does secure data mean for us?
  • How do we prove we are compliant?
  • How do we identify what are risks are?
  • How do we manage these risks?
  • What do we do next?

An example of risk that we all now know about
The Panama Papers are 11.5 million leaked documents that detail financial and attorney–client information for more than 214,488 offshore entities.

The leaked documents were created by Panamanian law firm and corporate service provider Mossack Fonseca; some date back to the 1970s.
The company informed clients on 3 April 2016, that files had been obtained through a hack of the company’s email server. Forbes has suggested that the firm’s information security was poor, running old versions of key tools, and other vulnerabilities.

At QCS, we are often asked, where do we begin?

Step 1 – By conducting a gap analysis an organisation can establish what is already in place and then include it in the system, or adjust it where necessary to show conformance with ISO 27001. This is usually easier than trying to do everything from scratch.

We find in our work that many organisations are already meeting many of the requirements within their own procedures and arrangements. A gap analysis measures these against the standard and makes recommendations on what must happen if certification is to be achieved. The output of such analysis tends to be an action list.

The gap analysis shall suggest what procedures need to be changed/introduced, what controls are necessary for ISO 27001 certification, training needs for staff and the development of a system to review and check the effectiveness of controls introduced.

The kinds of documentation and action required to lead you to conformance with the standard include:

  • Issuing and adoption of Information Security Policy
  • Establishment of key information security objectives and measures – to demonstrate improvement and to drive change
  • Review and adoption of effective procedures for HR, IT systems, Admin, Finance and Software
  • Understanding your assets, and how these are to be managed
  • Adoption of applicable controls as described within ISO 27001
  • Risk Assessment procedures
  • Audits, inspections and reviews on the effectiveness of arrangements
  • Management Reviews – making decisions on changes and improvements

It can be daunting to start the process, however, the cost of ignoring the risks to your information security systems, no matter how small, can be considerable. QCS International can help you to understand the process and ensure you have the necessary skills to manage the system yourselves.

Find out more by attending one of our ISO 27001 courses or giving us a call to see how we might be able to assist.

The post ISO 27001 Meeting the needs of the Legal Profession appeared first on QCS International.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

Having survived the maelstrom of awareness training and activity leading up to the implementation of GDPR in May 2018, organisations holding data have had a lot on their plates in recent times.

As many organisations are starting to realise, the wider management of Information Security is not a quick fix but a cycle of continual development and testing. Thankfully, there’s an existing framework in ISO 27001:2013 on which to build.  This is the management system that provides assurance to you and your clients that you are identifying vulnerabilities and controlling threats in a systematic way.

A component of your business may be that you regularly receive, control or capture personal records or other data for your own staff, clients or members of the public.  Perhaps you develop software and systems or perhaps some of the updates from the ICO (Information Commissioners Office) have led to a focus on cyber security?

A fully implemented ISO 27001:2013 Information Security Management System provides your organisation with structure to manage the risks of handling your data and requires robust mechanisms to be in place to meet regulatory requirements.  Having it independently certified provides further assurance to interested parties that the risk is being managed effectively. The outcome, if all is managed and implemented effectively, will contribute towards any ‘zero breaches’ objectives you have.

For those who are already registered to ISO 9001 you will find than ISO 27001 can be fully integrated within this management system. (Similarly, if you have ISO 27001 you can develop this to include ISO 9001 if you wish).

Achieving certification demonstrates commitment to keeping your clients’ data confidentially, together with complying with Data Protection Legislation of the UK and EU.

It’s all too easy to fall foul of UK and EU legislation and the fines and bad publicity as a result of a breach of security have very long reaching effects on your business – not just financial.

To find out more about preparing for ISO 27001 and to see what you can to develop a system to minimise the risks you face please go to Blog 2 in this series.

The post Information Security: ‘Zero Breaches’ through ISO 27001 appeared first on QCS International.

Read Full Article

Read for later

Articles marked as Favorite are saved for later viewing.
close
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

Separate tags by commas
To access this feature, please upgrade your account.
Start your free month
Free Preview