Data security, support and archiving

What can be disclosed?

The University takes the view that all agreed marks awarded should be disclosed to students, because of the educational value of feedback on assessed work. Evidence of recent medical problems etc. should have been considered by this stage in the process (see Annex C: Consideration of mitigating circumstances by examiners). Degree classification will continue to be a matter for boards in accordance with their examination conventions using the complete set of standardised marks. 

What is confidential?

It is University policy that examiners’ comments, exam scripts and raw marks (i.e. the marks from individual examiners before agreement or reconciliation) are strictly confidential and in no circumstances may be shown to or discussed with anyone other than examiners or properly appointed assessors. Details of the discussions at examiners’ meetings are equally confidential. Apart from the chair, only authorised administrative staff may process the entry of marks and otherwise assist in the handling of information.

The General Data Protection Regulation/Data Protection Act 2018 (GDPR/DPA 2018) entitles an individual to make a subject access request in order to obtain a copy of any personal data held about them. Personal data is any information that relates to an identifiable individual, including information about their performance in an examination such as marks and examiners’ comments.

All subject access requests submitted to the University are processed centrally by the Information Compliance team in the Council Secretariat. Under no circumstances should examiners, assessors, or administrative staff respond to direct requests for disclosure of information relating to the exam. Those wishing to make such a request should be advised to contact the Information Compliance Team in the Council Secretariat at data.protection@admin.ox.ac.uk. Under GDPR/DPA 2018, fees are no longer charged for subject access requests.

The right of subject access under GDPR/DPA 2018 means that students may access information that is otherwise treated as confidential. By making such a request a student may obtain all personal data generated as part of the exam process, including:

• all marks held, including raw marks;
• copies of markers’ comments on their work;
• (if identifiable separately from other individuals) comments recorded about their performance, whether by name or candidate number, in material presented to or in the minutes of examiners’ meetings; and
• any other information relating to their performance, such as information about medical problems.

However, due to a specific provision in GDPR/DPA 2018, exam scripts are exempt from this general right of access, although a student is still entitled to any marks or comments recorded in the margins of a script.

It should be noted that when responding to a subject access request for exam-related information, the Information Compliance team redacts the names of examiners in order to preserve the anonymity of the exam process. For the same reason, the team will also transcribe any handwritten comments, although may need to ask individual examiners to do this where the handwriting is not legible.

Supervisory bodies should ensure that all examiners acting on their behalf are aware of the Proctorial requirements relating to the retention of records as detailed in the Exams Handbook. 

The GDPR/DPA 2018 requires that personal data should not be kept for longer than is necessary to meet the purpose for which it is being processed. In the light of this, the Proctors instruct the examiners, once the exam is complete and the final list produced, to do the following as regards retention of records:

Hard copy records

• Each examiner and assessor, including external examiners, should hand over to the chair of examiners all material in their possession pertaining to the marking of the exam. This includes mark sheets, mark books, and notes on individual written answers and on vivas. They must sign a declaration that they no longer have such material in their possession. External examiners are permitted to wait until they have submitted their report before handing over this material and signing the declaration.
• The chair of examiners should retain these records, and records relating to the adjudication of candidates, including records of those scripts which were remarked or on which the external examiner’s advice was sought, and the outcome; all medical evidence including a note, which must be countersigned by external examiner(s), of any actions taken in reaching the final marks and degree results; the declarations of examiners. All this material must be deposited with the nominated administrative officer and retained for two years after the final examiners’ meeting. Duplicates and confidential waste must be destroyed (this means shredded, not put intact in a bin).
• Appeals against final results are normally only possible within 20 working days after the publication of results, although it is prudent to keep all records for two years. Records should not be destroyed if an appeal to the Proctors is in progress.    
• If, during an exam itself or during classification of results, any automated processing or weighting of results takes place, the chair should be able to provide a formal statement that explains the logic behind any such processing. If an assessment itself is based partly on automated means (e.g. multiple choice tests) which form only a part of a larger assessment, the procedure for combining different sets of marks should be available.
• The above arrangements apply to each completed exam (including the previous parts of a multi-part FHS). In a multi-part exam, scripts and other submitted work, and notes on performance, must be retained (for consideration by the following year’s examiners) until all parts of the exam are complete.
• It remains the University’s policy that results (i.e. the final marks that have been agreed, scaled and moderated) should be made available to candidates through their colleges (and via the student record system) at the end of the exam process. As indicated above, raw marks should not be disclosed to colleges or candidates (see separate section on the provision of reconciled question-level marks).

Electronic records

Items which it is necessary to retain in electronic form include only such data to which there would be no objection to a candidate’s having access, including final class and agreed marks on individual papers. This data should be retained for two years after the final examiners’ meeting. These provisions have particular implications for chairs of examiners in Schools with multiple parts. In these cases, records should be retained for two years after the final examiners’ meeting for the final part.

Data from the exam may be kept in electronic form for subsequent purposes (e.g. evaluating proposed changes in examining procedures, such as changes in paper weightings) beyond the time limit mentioned above provided the information is depersonalised and does not contain items that should not be divulged (such as raw marks).

The nominated administrative officer should retain copies of all the agreed marks, and any notes relating to them, for two years after the final meeting. This is necessary in order to deal with examination queries, complaints, and appeals, and to handle cases in which candidates carry forward their marks in the written papers to the following year, for example, when resubmitting only their dissertations.

Outgoing chairs should keep records for the assistance of future chairs on matters such as special problems encountered and arrangements made with the Head of Exams and Assessments. The records should take the form of a chair’s book, which can be passed on each year. It is very important that chairs transmit to their successors any medical certificates and ongoing permissions (i.e. in relation to SpLD arrangements) for candidates likely to be resitting the exam, or any element of it. Reports are available via the SITS student record system of all approved alternative arrangements. It is preferable if these materials are deposited with a member of the Faculty/Departmental administrative staff who will arrange for onward transmission.

Further details about retention of records can be found in the Examinations and assessments framework (EAF). 

Storage 

• Scripts and exam submissions in the possession of examiners and assessors must be locked away, particularly before they have been marked.

• Faculties and departments are permitted to retain scripts and submissions, if they can provide suitable storage space.

• Hard copy scripts/submissions may be stored in the Examination Schools if preferred, but will be destroyed six months after the publication of results.

• Digital scripts/submissions submitted will be held for three years and hard deleted (where scripts are anonymised but remain indefinitely for analytic purposes) after that point.

• Scripts and submissions should be packaged securely in boxes, clearly labelled with the name of the exam and the term and year, with the course code/paper numbers and in candidate number order. 

Retrieval  

• In the event of a student intermitting, or submitting an appeal or complaint, faculties and departments are responsible for retrieving and retaining the candidates’ work; whether held locally or at the Examination Schools.

• These guidelines include the secure electronic storage of summative assessments submitted online.

• The Proctors’ Office will notify the relevant faculty or department on receipt of a complaint or appeal, requesting that all of the papers completed by the candidate in that academic year should be located and retained by the faculty/department.

• Similarly, officers in Education Policy Support will notify the relevant faculty/department if a student has received a completion of procedures letter following an application to Education Committee.

• Once the investigation of the complaint or appeal is complete, the Proctors’ Office will provide a date for destruction that is two years after the completion date of the investigation of the appeal or complaint or the predicted completion date of the student’s course, whichever is the longer.

• Scripts retained as a result of this process must be stored within faculties/departments as there are no facilities at Examination Schools or the Proctors’ Office for long-term storage.

• Scripts must be stored securely and shredded when the date for destruction has passed. 

Storing scripts at the Examination Schools 

• Contact exams@admin.ox.ac.uk to book an appointment to deposit scripts. We may not be able to accept archiving where no appointment has been made.

• In the case of multi-part exams, scripts/submissions sent to the Examination Schools will be retained until six months after results are released for the final part of the exam.

• Ensure each archive box is clearly labelled with the course, candidate numbers, and year, using the Archive Label template

• All comment sheets and mark sheets are removed and retained by the relevant Department to ensure comments can be easily located in the case of a request, made under the Data Protection Act for a candidate to read all written comments about their work

• Refer to the script archive guidance when preparing work for storage 

Research Degree theses 

• After the release of the results for the exam, copies of theses that are required to be deposited at the Bodleian Library should be delivered to the Head of Exams and Assessments, who will record them and arrange delivery.

• Where a board requires a candidate to make minor corrections to a thesis before deposit at the Bodleian Library, the candidate should submit the revised version to Exams and Assessments and not directly to the Bodleian Library.

• Where theses are deposited with another library (e.g. in the department), chairs should make the necessary arrangements.