Quite few of my clients have asked me about guidance from the ICO regarding exam script exemptions. Their guidance can be found at:
The main point is that the answer is yes, the exam scripts exemption will still apply to the information used to award students’ grades. This means that you don’t have to provide a response to requests from students for information about their provisional grades, including the teacher assessments and/or rank orders, until after the results are published.
If you receive a request from a student before the official results are announced then the exemption allows for longer response times. The time-frame for responding to these requests is either:
within five months of receiving the request; or
within 40 days of announcing the exam results, whichever date is earliest.
Requests made after the results are announced need to be dealt with as a normal subject access request, i.e. within one month of receipt of the request.
However, the ICO understands there may be delays during the pandemic and they have published a document setting out their regulatory approach during the coronavirus pandemic.