Subject access request case and disclosure decision record
- Version
- v1
- Updated
- 7 October 2026
- Reviewed
- 7 October 2026
- Audience
- School data protection leads, designated case handlers, senior decision-makers and staff supporting the handling of subject access requests.
- Jurisdiction
- england
Blank fields · read-only preview
1. Case identification and scope
Complete this record for a subject access request received by the school. Complete fields only where relevant and record the case-specific rationale for any fee, redaction, withholding, extension or alternative access route.
Case reference
RequiredUse the school's case reference format.
Enter case reference
Case handler
RequiredRecord the name or role of the person responsible for coordinating this case.
Enter name or role
Date the request was received
RequiredRecord the date on which the school received the subject access request.
- Day
- Month
- Year
How was the request received?
RequiredSelect all applicable channels.
Choose all that apply
- Online form
- Letter
- In person
- Telephone
- Request received through a representative
- Other
If other, please specify
Summary of the request and information sought
RequiredDescribe the request accurately, including the people, records, subjects and time periods covered.
Summarise the request
Relationship of requester to the data subject
RequiredSelect the relationship relevant to the request.
Choose one
- The requester is the data subject
- Parent
- Guardian or person with parental responsibility
- Authorised representative
- Professional representative
- Other relationship
- Other
If other, please specify
Data subject name
RequiredRecord the name of the person whose personal data is requested.
Enter full name
Requester name
RequiredRecord the name of the person who submitted the request.
Enter full name
Requester identity and authority status
RequiredIf the requester is acting for a child or another person, clarify authority before responding where authority or representation is unclear. Record the evidence relied on in the rationale field.
Choose one
- Requester identity confirmed; requester is the data subject
- Requester identity and parental responsibility or authority confirmed
- Requester identity and data subject consent confirmed
- Authority not required for this request
- Clarification or evidence of authority requested
- Authority remains unresolved
- Other
If other, please specify
Identity and authority rationale
Record the checks completed, evidence considered, clarification requested and any unresolved issue. Complete where the requester is not the data subject or authority is relevant.
Record the rationale and evidence
Was the school closed for a holiday or other closure period when the request was received?
RequiredRecord the status for deadline calculation. A school closure does not create a school-holiday extension to the normal response period.
Choose one
- No, the school was open
- Yes, the school was closed
- Partially closed or limited service
- Status not known
Calculated response deadline
RequiredCalculate and record the applicable deadline. Do not add a school-holiday extension solely because the school was closed.
- Day
- Month
- Year
Was an extension considered or applied?
RequiredComplete only where an extension is relevant. Record the reason, decision-maker and communications in the rationale field.
Choose one
- Not considered
- Considered but not applied
- Applied
- Pending decision
Extension rationale and communication
Complete if an extension was considered or applied. Explain the case-specific basis, dates, decision-maker and what was communicated to the requester. Be as transparent as possible, subject to any applicable restriction.
Record the rationale and communication
Date the case was closed
Complete when the response and any follow-up actions are complete.
- Day
- Month
- Year
2. Information scope, searches and preservation
Information categories within the request
RequiredSelect all categories searched or assessed.
Choose all that apply
- Educational record
- Pupil or student file
- Attendance records
- Assessment or examination records
- Correspondence and emails
- Safeguarding records
- Health information
- Behaviour or disciplinary records
- Staff or employment-related records
- Other information category
- Other
If other, please specify
Searches and custodians checked
RequiredDescribe the systems, locations, date ranges, custodians and search terms used, including any unsuccessful searches.
Record the search methodology and results
Information preservation status
RequiredRecord the steps taken to preserve potentially responsive information. Do not alter, block, erase, destroy or conceal information to prevent disclosure.
Choose all that apply
- No additional preservation action needed
- Preservation hold or equivalent control applied
- Existing retention controls confirmed
- Potential preservation issue identified
- Unable to confirm preservation status
- Other
If other, please specify
Preservation rationale and evidence
RequiredRecord controls applied, relevant retention arrangements, issues identified and escalation or remedial action.
Record preservation actions and evidence
3. Fee assessment
Fee decision
RequiredDo not charge a fee as a general practice for an education-information subject access request. Complete the fee rationale if a fee is considered or charged.
Choose one
- No fee
- Fee considered but not charged
- Fee charged
- Fee decision pending
Fee amount
Complete only if a fee was charged or is proposed. Record the amount in the school's currency.
Number
Minimum: 0
Fee rationale and communication
Complete if a fee was considered, charged or proposed. Explain the case-specific basis, evidence, decision-maker and communication to the requester.
Record the fee assessment and communication
4. Third-party information
Does the responsive information contain personal information about other people?
RequiredConsider third-party information before disclosing education information.
Choose one
- No third-party personal information identified
- Third-party personal information identified and assessed
- Potential third-party personal information identified; assessment pending
Third-party disclosure decision
Complete where third-party personal information is present or potentially present.
Choose one
- Disclose without redaction
- Disclose with redaction or removal
- Withhold the third-party information
- Seek further consultation or decision
- Not applicable
Third-party assessment and rationale
Identify the relevant information, people affected, consultation or consent considered, disclosure decision and redaction or withholding rationale.
Record the third-party assessment
5. Serious-harm assessment
Is a serious-harm assessment relevant to the requested education information?
RequiredComplete the assessment where disclosure would need to be considered against the serious-harm test.
Choose one
- Not relevant
- Considered; serious harm not likely
- Considered; serious harm likely
- Further specialist assessment required
Serious-harm assessment and rationale
Complete where relevant. Record the information assessed, people potentially affected, evidence, decision-maker, scope of any withholding and what could be explained to the requester.
Record the serious-harm assessment
6. Lawful alternative information-access routes
Was an alternative information-access route relevant?
RequiredDo not require a person to make a subject access request where another lawful route is appropriate. Complete only where relevant to the information sought.
Choose all that apply
- No alternative route identified
- Criminal disclosure regime considered or signposted
- Access to Medical Reports Act 1988 route considered or signposted
- Other lawful information-access route considered or signposted
- Specialist advice required before selecting a route
- Other
If other, please specify
Alternative route rationale and communication
Explain why the route was relevant, what information it covers, whether the SAR was still processed, and what was communicated. Do not state that a requester was required to make a SAR for information that should be accessed through another route.
Record the alternative route assessment
7. Disclosure and withholding decision
Overall response decision
RequiredSelect the decision that applies after completing the relevant assessments.
Choose all that apply
- Disclose all responsive information identified
- Disclose some responsive information with redactions or exclusions
- Withhold all responsive information
- Request clarification before final decision
- Pause pending identity or authority clarification
- Provide or signpost an alternative lawful access route
- No responsive information located
- Other
If other, please specify
Description of redacted, excluded or withheld information
Complete where information was redacted, excluded or withheld. Identify the material and scope without unnecessarily reproducing sensitive information.
Describe the information and decision scope
Disclosure, redaction or withholding rationale
RequiredRecord the case-specific reasoning, evidence, decision-maker, scope of the decision and any relevant limitation on explaining the decision to the requester.
Record the final decision rationale
Decision-maker
RequiredRecord the name or role of the person who approved the disclosure or withholding decision.
Enter name or role
8. Response communications and retained evidence
Date the response was sent
Complete when the final response was issued.
- Day
- Month
- Year
How was the response provided?
Select all methods used.
Choose all that apply
- Secure email
- Post
- Secure portal
- In person
- Telephone follow-up
- Other
If other, please specify
Response content and communications record
Summarise what was disclosed, redacted, withheld or signposted, including any explanation of decisions, clarification requests, extension communications and delivery details.
Record the response communications
Retained evidence and record locations
RequiredList the retained request, identity or authority evidence, search log, decision record, redaction schedule, correspondence, disclosure copy and delivery evidence, with their approved storage locations.
List retained evidence and storage locations
Outstanding follow-up actions
RequiredRecord any unresolved action, owner and target date. Enter none if no follow-up is required.
Record outstanding actions or enter none
Record completion confirmation
RequiredConfirm that the relevant sections have been completed, supporting evidence has been retained and the final decision has been reviewed.
- Tick when complete
