Know the Differences in Process from 2020

As another extraordinary results season looms, schools and academy trusts need to be ready for the changes compared to the processes of 2020. Updated guidance was published by the DfE on 25th February 2021, explaining these changes.

This post covers the data protection aspects of these changes.

One of the key differences is around appeals.

  • In 2020, Centre Assessed Grades (CAGs), were made based on a centre’s judgement of the grade a student would most likely have achieved had they taken their exams. The evidence used to inform this judgement could not be specified as only evidence that already existed could be used. The process to be followed by schools and colleges was not prescribed. This meant that students could not appeal against their CAGs as there was no basis on which they could appeal the judgement.
  • In 2021, all students will be able to appeal. Basing the grades on an assessment of the students’ performance towards the end of the academic year means there will be evidence that could be considered in an appeal.

With this in mind, it is strongly recommended that before a grade is submitted, students are made aware of the evidence teachers are using to assess them. Students will then have the opportunity to confirm the evidence is their own work and make their teachers aware of any mitigating circumstances they believe should be taken into account.

With clear processes being communicated, and moderation sampling being undertaken by the exam boards, schools and colleges will have clarity as to the standards at which students are performing and, therefore, be able submit a grade that reflects that standard. Schools and colleges are also no longer required to put their students into a rank order. With this information no longer necessary, students will not be able to request to see it as was the case in 2020.

Taking these changes in to account, we feel that schools and colleges are less likely to being faced with Subject Access Requests (SARs) from parents/students seeking clarification of why they received certain grades this year. Nevertheless, we have set out below some key processes that you should have in place in preparation for the awarding of qualifications.

We’ve used our experience as school leaders, and the changes in the process of awarding qualifications, to put together a simple guide to help schools handle this process:


  1. Schools and colleges should make students aware of the evidence teachers are using to assess them for each qualification. Advice on this and what evidence can be used, can be found here.
  2. Students should be made aware that they being graded on their current performance and not their potential. Therefore, schools and colleges should ensure students communicate early any mitigating factors or issues they feel should be taken into account.
  3. Enter all CAGs by 18th June 2021.
  4. Set out clear procedures that are communicated with students on how to appeal following Results Day should they wish.
  5. If a student wishes to appeal, schools and colleges should undertake an initial review to check all processes were followed correctly and no errors were made. The school should communicate these findings with the student.
  6. If the student still wants to appeal, they will need to ask the school or college to submit a formal appeal to the exam board for them.
  7. The exam board will check the school or college followed its own processes and the exam board requirements, as well as reviewing the evidence used to form their judgement.

Whilst we have already noted that the changes in process this year mean that it is less likely for students / parents to submit SARs regarding their results, it is still possible that there may be requests that are submitted. If that happens, here is some guidance to assist with them:


  1. Make sure requests are made by pupils only. Parents can only make a request with the pupil’s permission.
  2. Deal with concerns and requests informally at first, with the option to hold informal discussions with pupils who either express concern or make a request. Not every request needs to be formalised as a SAR. Provided the request is straightforward, you can provide the data requested. This will save paperwork and time. This will, of course, depend on the complexity of the data requested.
  3. You may wish to assign a specific colleague to deal with the administration of requests (collecting relevant data etc). This will make it easier when dealing with straightforward requests. If you are unsure whether to treat a request as a SAR, we would be happy to advise.
  4. If students are not happy to resolve the matter informally with the school, they can submit a SAR.
  5. If you get a number of informal requests, keep an evidential record of who has made the request, the date of the request, and the response and what has been provided. This will help if the matter is escalated to the ICO (Information Commissioner’s Office). If they become a formal SAR request, they can be logged appropriately.

The Information Commissioners Office (ICO) are yet to update any changes to guidance regarding the awarding of qualifications for the summer of 2021. If this changes we will be in contact with our schools to ensure they are aware of any changes to processes.

For further assistance with this or any other data protection matter please make contact with us at 

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