The AI Request Avalanche

Why Schools Are Facing an Unprecedented Surge in Complex SARs, FOIs and Complaints

Why Schools Are Facing an Unprecedented Surge in Complex SARs, FOIs and Complaints

Is artificial intelligence making it easier to complain than to resolve a complaint? Across schools and academy trusts in England and Wales, a growing administrative problem is emerging. Headteachers, school business managers, governors and Data Protection Officers (DPOs) are increasingly having to deal with lengthy, complicated and sometimes confrontational correspondence that appears to have been produced, or substantially expanded, using artificial intelligence (AI).

What might once have been a straightforward conversation with a teacher, a short email to the headteacher or a simple request for information can now arrive as a ten-page document containing legal arguments, demands for evidence, references to legislation and threats of escalation to regulatory authorities.

The issue is not necessarily that parents and other individuals are making more requests. It is that AI can turn a relatively simple concern into a disproportionately complicated administrative exercise, often without improving the substance of the original complaint.

For schools already facing considerable financial and staffing pressures, the consequences can be significant.

AI has made formal complaints easier than ever

There is, of course, a positive side to this development. AI tools such as CoPilot or ChatGPT can help people who struggle with written communication, have English as an additional language or are unfamiliar with formal complaints procedures. They can help individuals explain genuine concerns, understand their rights and communicate more effectively.

That is a welcome development. Schools should not expect parents to have legal knowledge or administrative experience before raising concerns. However, there is a considerable difference between using AI to explain a genuine problem clearly and using it to manufacture a lengthy, legalistic complaint that bears little resemblance to the original issue.

A disagreement about a playground incident, for example, might previously have resulted in a telephone call or a brief exchange of emails. Today, the same issue could generate a document demanding disclosure of records, an investigation into alleged safeguarding failures, explanations of statutory responsibilities, copies of policies and a formal response to numerous individual allegations.

The underlying concern may be perfectly legitimate. The additional complexity may not be.

When one page becomes forty

One of the most noticeable consequences of AI-generated correspondence is the extraordinary increase in its length. A BBC News report has highlighted concerns about complaints to public bodies expanding from relatively short correspondence into documents running to many pages.

The problem for schools is that the time needed to produce a request is no longer remotely comparable with the time required to investigate and answer it. A parent might spend five minutes asking an AI chatbot to produce a comprehensive complaint. The school could then spend several days identifying the actual concerns, reviewing records, consulting staff, checking legal references and preparing an appropriate response.

AI-generated correspondence can also be repetitive. The same allegation may appear in several sections, expressed in different language and accompanied by slightly different questions. The recipient is left trying to establish whether there are genuinely several separate issues or merely one concern repeated in numerous ways.

This is not an efficient use of limited school resources.

The danger of AI-generated legal expertise

Perhaps the most troubling aspect is the apparent authority of AI-generated correspondence. AI systems can produce convincing legal language. Unfortunately, convincing language does not necessarily mean accurate information.

A complaint might refer to legislation that does not apply, misunderstand the responsibilities of a school or quote legal principles without considering their relevance.

Some correspondence may even contain invented case law or incorrect interpretations of statutory duties. Schools must distinguish between genuine legal obligations and demands that simply sound authoritative.

A particularly important distinction concerns Subject Access Requests and Freedom of Information requests. A Subject Access Request is not a general entitlement to every document held by a school. It concerns the requester's personal data, subject to the relevant legislation and exemptions. Similarly, the Freedom of Information Act 2000 does not require a school to create information it does not hold simply because an applicant has requested it. There may be circumstances in which information can be withheld, a request clarified or the applicable statutory provisions relied upon to manage unreasonable demands.

The important point is that schools should not automatically accept the legal interpretation contained in an AI-generated letter. Equally, they should not dismiss a request merely because AI appears to have been used.

SARs, FOIs and complaints are not interchangeable

One of the recurring difficulties is correspondence that combines several different statutory and administrative processes. A single letter might include a parental complaint, a SAR, an FOI request, questions about safeguarding and demands for explanations of decisions.

These matters need to be identified and handled under the correct arrangements.

For example:

• Subject Access Requests: Governed principally by the UK GDPR and Data Protection Act 2018, as amended, including relevant changes introduced by the Data (Use and Access) Act 2025. Schools should apply the rules on reasonable and proportionate searches, clarification where appropriate, exemptions and manifestly unfounded or excessive requests.

• Freedom of Information requests: Governed by the Freedom of Information Act 2000 for schools in England and Wales, with separate rules on costs, exemptions, vexatious requests and information not held.

• School complaints: Managed through the applicable school complaints procedure and relevant statutory or regulatory requirements.

• Safeguarding concerns: Must be assessed on their substance and urgency, regardless of the format or tone of the correspondence.

A school should not allow an AI-generated document to blur these distinctions. Nor should it assume that an unnecessarily lengthy submission automatically qualifies as vexatious, excessive or manifestly unfounded. Those are legal tests requiring proper consideration of the circumstances.

Are we losing the ability to talk to one another?

There is another consequence that is potentially more damaging than the administrative workload. Schools depend upon constructive relationships with parents and carers. Most disagreements are best resolved through communication, explanation and a willingness to listen. However, AI can encourage an unnecessarily adversarial approach, particularly when users ask it to make a complaint more forceful, more legalistic or more difficult to challenge. Instead of asking a teacher why something happened, a parent may send a formal allegation of misconduct. Instead of seeking clarification about a school decision, they may demand an investigation and threaten referral to external bodies.

Legal specialists Browne Jacobson have highlighted the challenges associated with managing school complaints and data requests in the AI era. The danger is that communication becomes a contest rather than an attempt to resolve a problem. The child, whose interests should remain central to the discussion, can become almost incidental to the process.

The hidden cost to education

Every hour spent responding to unnecessary administrative complexity is an hour unavailable for something else. For a large academy trust, the work may be distributed across legal, governance, administrative and information governance teams. For a small primary school, it may fall largely upon the headteacher and a school administrator.

Consider the cumulative effect of receiving several lengthy complaints, SARs and FOI requests in a single month. Staff may need to search emails, retrieve archived records, consult colleagues, review potentially sensitive personal information, consider exemptions, undertake redactions and prepare responses.

Where allegations are made against individual employees, additional care may be necessary to protect confidentiality, employment rights and staff wellbeing. There can also be a considerable psychological impact. Being repeatedly confronted with formal accusations, legal threats and demands for immediate action can be distressing, particularly when the correspondence concerns relatively minor disagreements.

It would be wrong to suggest that every complaint is unjustified or that AI-generated correspondence is necessarily unreasonable. Nevertheless, the cumulative pressure deserves recognition. Schools exist to educate children, not to operate as permanently staffed legal correspondence departments.

What can schools do?

The answer is not to discourage people from exercising their rights. It is to manage requests lawfully, consistently and proportionately.

Schools should consider the following practical measures:

1. Identify the actual request. Separate complaints, SARs, FOIs and safeguarding matters rather than treating every paragraph as a separate legal demand.

2. Encourage early dialogue. Where appropriate, offer a conversation to clarify concerns and explore a resolution, without obstructing statutory rights or delaying applicable deadlines.

3. Seek clarification where legally permitted. The UK GDPR, as amended, provides for clarification in appropriate SAR circumstances. FOI clarification operates under different rules. Schools must understand the effect on statutory timescales.

4. Apply the correct legal tests. Consider relevant exemptions, cost limits and provisions relating to manifestly unfounded, excessive or vexatious requests where the evidence supports their application.

5. Do not create unnecessary work. FOI generally concerns recorded information already held. Schools are not ordinarily required to complete bespoke questionnaires or manufacture new datasets.

6. Keep comprehensive records. Record requests, decisions, searches, correspondence, deadlines and outcomes in an appropriate information governance register.

7. Support staff. Ensure that headteachers and administrative colleagues have access to appropriate guidance and support, including their DPO where data protection matters arise.

8. Review complaints procedures. Make them accessible, fair and effective, while providing appropriate arrangements for persistent or unreasonable behaviour.

The Information Commissioner's Office provides guidance on Subject Access Requests and Freedom of Information that should inform school procedures.

Schools should also be cautious about introducing mandatory word limits or online-only submission systems. These must not obstruct statutory information rights, exclude people with accessibility needs or prevent genuine safeguarding concerns from being raised.

Could schools use AI to fight back?

There is an obvious irony in this situation. If AI is being used to generate increasingly complicated correspondence, could schools use AI to help analyse it? Potentially, yes.

AI can assist with identifying themes, summarising lengthy correspondence, preparing draft responses and highlighting questions that require further consideration.

However, schools must exercise considerable caution. Uploading complaints, pupil records, safeguarding information or staff personal data into an unapproved public AI system could introduce serious data protection and confidentiality risks.

Any school use of AI must comply with its information security arrangements, data protection obligations and relevant policies. AI-generated summaries and draft responses must also be checked carefully by someone with the necessary knowledge and experience.

AI should support professional judgement, not replace it.

A final thought: Just because you can, does it mean you should?

AI is undoubtedly a valuable technology. Used intelligently, it can improve communication, increase accessibility and help individuals understand their rights. However, the ability to generate a 30-page complaint in seconds does not mean that producing one is necessary, proportionate or helpful. The same applies to demands for information.

A well-written, focused SAR or FOI request is generally more useful than a sprawling document containing dozens of loosely related questions.

Schools must respect legitimate requests and complaints. Parents and others must be able to challenge decisions, raise concerns and exercise their statutory rights without unnecessary barriers. But there also needs to be recognition that school resources are finite.

The growing ease with which AI can generate administrative demands risks creating an imbalance between the effort required to make a request and the resources needed to answer it. Ultimately, the solution will require a combination of better public understanding, sensible use of technology, effective school procedures and proportionate application of existing legislation.

Perhaps the most useful question anyone could ask an AI chatbot before sending a complaint is not, "Can you make this longer and more legally forceful?" but, "Can you make this shorter, clearer, more accurate and more likely to resolve the problem?" That would be a much better use of artificial intelligence.

Steve Cullen, Insight Management Services and Information Governance Ltd (Insight MSIG)

Supporting schools and academy trusts with data protection, information governance and practical compliance advice.

Editorial note: This blog deliberately avoids presenting an unverified percentage increase in AI-generated requests or attributing all increases in complaints to AI. The distinction between legitimate requests and unreasonable administrative complexity is important.