Access Arrangements - External Examinations 2023-24

AuthorityDepartment of Education, Sport and Culture
Date received2024-12-03
OutcomeUpheld - partial
Outcome date2025-03-28
Case ID4294229

Summary

A request was made for access arrangement policies and statistics for external examinations across Isle of Man secondary schools for the 2023-24 academic year. The Department of Education partially upheld the request, providing some policies and data while citing that certain information was not held or was already publicly accessible.

Key Facts

  • The request covered five schools: Ballakermeen High, Castle Rushen High, Ramsey Grammar, St Ninian's High, and Queen Elizabeth II High.
  • Castle Rushen High School provided specific counts of external requests for access arrangements (65 for Year 11, 24 for Year 13).
  • Several schools stated they did not hold specific data on the number of requests made or granted for access arrangements.
  • Ballakermeen High School's policy was deemed reasonably accessible via their website rather than provided directly.
  • Some data regarding scribe usage was redacted because the number of pupils was less than five.

Data Disclosed

  • 2023-24
  • 2024-12-03
  • 2025-03-28
  • 65
  • 24
  • 297
  • 211
  • 145
  • 65
  • 162
  • 119
  • 159
  • 138
  • 40
  • 21
  • 16
  • 7
  • 72
  • 18
  • 107
  • 131

Exemptions Cited

  • Section 20 (Information already reasonably accessible)
  • Section 25(b)(i) & (ii) (Redaction for less than five pupils)
  • Information not held or cannot be found after reasonable steps

Original Request

For each Island Secondary School, I seek the following information regarding access arrangements (any provisions made for students to ensure they can be validly assessed and are not unfairly disadvantaged due to disability, illness, EAL characteristics etc) for those external examinations held in the 2023-24 academic year: I) A copy of each school Access Arrangements Policy (however titled) and date of last review of such; and II) The number of external requests for (a) Level 2 and (b) Level 3 examinations (i) made and (ii) granted for approved access arrangements; and III) The total number of pupils entered for (a) Level 2 and (b) Level 3 examinations; and IV) The number of approved access arrangements for (a) Level 2 and (b) Level 3 by type of arrangement e.g. 25% extra time, scribe or speech recognition, computer reader or reader, extra time over 25% and such other categories for which access arrangements were made; and V) The number of approved access arrangements for (a) Level 2 and (b) Level 3 by reason e.g. disability, pupil's first language not English etc; and VI) The number of modified paper requests for (a) Level 2 and (b) Level 3 examinations (i) made and (ii) granted for each school; and VII) For those modified requests granted for (a) Level 2 and (b) Level 3 examinations the number by type e.g. 24 point font etc. VIII) The number and type of access arrangements implemented by each school without recourse to external examination board approval for (a) Level 2 and (b) Level 3 examinations.

Data Tables (2)

Date October 2024
Review date October 2025
Role
SENCo
Exams Officer
IT manager

Full Response Text

Please see below our response to your request (I- IV). I) A copy of each school Access Arrangements Policy (however titled) and date of last review of such; Ballakermeen High School While our aim is to provide information wherever possible, under section 20 of the Act, we are not required to provide information in response to a request if it is already reasonably accessible to you, whether free of charge or on payment of a fee. By way of advice and assistance Ballakermeen High School’s Access Arrangements Policy can be viewed via the school’s website - https://bhs.sch.im/site/uploads/pages/14/ media/20230712 4e851d46/Access Arrang ements_Policy_2022_23.pdf
Castle Rushen High School Please find enclosed a copy of Castle Rushen High School’s Word Processing Policy. Ramsey Grammar School Please find enclosed a copy of Ramsey Grammar School’s Access Arrangement Policy. St Ninian’s High School Please find enclosed a copy of St Ninian’s High School’s Access Arrangement Policy. Queen Elizabeth II High School While our aim is to provide information whenever possible, in this instance the public authority does not hold or cannot, after taking reasonable steps to do so, find some of the information that you have requested. II) The number of external requests for (a) Level 2 and (b) Level 3 examinations (i) made and (ii) granted for approved access arrangements; Ballakermeen High School While our aim is to provide information whenever possible, in this instance the public authority does not hold or cannot, after taking reasonable steps to do so, find some of the information that you have requested. Castle Rushen High School Year 11 - 65 Year 13 – 24 Ramsey Grammar School While our aim is to provide information whenever possible, in this instance the public authority does not hold or cannot, after taking reasonable steps to do so, find some of the information that you have requested. St Ninian’s High School While our aim is to provide information whenever possible, in this instance the public authority does not hold or cannot, after taking reasonable steps to do so, find some of the information that you have requested. Queen Elizabeth II High School
While our aim is to provide information whenever possible, in this instance the public authority does not hold or cannot, after taking reasonable steps to do so, find some of the information that you have requested.
III) The total number of pupils entered for (a) Level 2 and (b) Level 3 examinations; Ballakermeen High School Level 2- 297
Level 3 – 211 Castle Rushen High School Year 11 - 145 Year 13 - 65
Ramsey Grammar School Level 2 -162 Level 3 – 119 St Ninian's High School
By way of advice and assistance, information relating to Level 2 and 3 examination results can be found by visiting St Ninian's High School's website- https://snhs.sch.im/pages/index/view/id/33/Exam%20Results%20Data Queen Elizabeth II High School Level 2 -159 Level 3 -138 IV) The number of approved access arrangements for (a) Level 2 and (b) Level 3 by type of arrangement e.g. 25% extra time/ scribe or speech recognition✓ computer reader or reader✓ extra time over 25% and such other categories for which access arrangements were made;
Ballakermeen High School Castle Rushen High School
Year 11: Extra time 40, Reader 21 & Scribe [Redacted - Less than five pupils]. Year 13: Extra time 16, Reader 7 & Scribe [Redacted -Less than five pupils].
Ramsey Grammar School Level 2- 72 Level 3 - 18
St Ninian's High School By way of assistance the total number of pupils with approved access arrangements was 107. Queen Elizabeth II High School By way of assistance the total number of pupils with approved access arrangements for Level 2 & 3 was 131.
Redacted Information s25(b )(i)&(ii)
While our aim is to provide information whenever possible, in this instance we are unable to provide some of the information included within the policy documents provided as it is absolutely exempt under section 25 of the Act (absolutely exempt personal information). The reasons why that exemption applies are that: •The Department of Education Sport and Culture is satisfied that the information amounts to personal data of which you are not the data subject; and •The Department of Education Sport and Culture is satisfied that disclosure of the information would contravene one of the data protection principles as set out at Article 5 of the General Data Protection Regulation as it applies in the Isle of Man pursuant to the Data Protection (Application of GDPR) Order 2018, namely that the Department of Education Sport and Culture can only disclose the information where it would be fair, lawful and meet one of the conditions for lawful processing in Article 6 and in this case, none of those conditions have been met. S39 (1)(a)(b)- Qualified exempt personal information While our aim is to provide information whenever possible, in this instance we are unable to provide some of the information held in respect of question IV, as in the instances where five or less pupils received access arrangements the Department determines that individual pupil's may be identifiable.
This information is exempt under Section 39 of the Freedom of Information Act 2015 (Qualified exempt personal information) as it constitutes personal data of a person other than you and under section 8 of the Data Protection Act 2002 the data subject would be entitled to prevent disclosure of the information to a member of the public otherwise than under that Act.
As Section 39 is a qualified exemption, it is subject to a public interest test. The public interest must be something that is of serious concern and benefit to the public at large.
Factors in favour of disclosing the information include: • To promote transparency & accountability. Factors in favour of maintaining the exemption include: • That pupils have a general expectation that the access arrangement support received will remain anonymised. Disclosure of this information would contravene that expectation and cause an intrusion into the privacy of the data subject which may lead to some distress. • Whilst the Freedom of Information Act 2015 promotes transparency and accountability and therefore there may be some public interest in individual pupil’s access arrangements being disclosed, it is not sufficient to outweigh an individual pupil’s right for this information to remain private. In assessing the weight to be attributed to each of the factors in favour of disclosing the information and maintaining the exemption, the Department of Education, Sport and Culture has taken the following into consideration: • The severity of the impact of the prejudice. • The age of the information. • How far disclosure would further the public interests identified above. • Whether there is any similar information in the public domain and whether this affects the public interest. Parts V-VII Further to our correspondence dated 16th December 2024, you may wish to submit a new Freedom of Information request for the remaining information (Part V – VII). This will allow the Department 20 working days to process your request and avoid the need to apply a practical refusal. Please quote the reference number 4294229 in any future communications. Your right to request a review If you are unhappy with this response to your freedom of information request, you may ask us to carry out an internal review of the response, by completing a complaint form and submitting it electronically or by delivery/post. An electronic version of our complaint form can be found by going to our website at https://services.gov.im/freedom-of-information/Review . If you would like a paper version of our complaint form to be sent to you by post, please contact me and I will be happy to arrange for this. Your review request should explain why you are dissatisfied with this response, and should be made as soon as practicable. We will respond as soon as the review has been concluded. If you are not satisfied with the result of the review, you then have the right to appeal to the Information Commissioner for a decision on; 1. Whether we have responded to your request for information in accordance with Part 2 of the Freedom of Information Act 2015; or 2. Whether we are justified in refusing to give you the information requested. In response to an application for review, the Information Commissioner may, at any time, attempt to resolve a matter by negotiation, conciliation, mediation or another form of alternative dispute resolution and will have regard to any outcome of this in making any subsequent decision. More detailed information on your right to a review can be found on the Information Commissioner’s website at www.inforights.im. Should you have any queries concerning this letter, please do not hesitate to contact me. Further information about freedom of information requests can be found at www.gov.im/foi. I will now close your request as of this date. Yours sincerely Information Governance Officer


1

Castle Rushen High School Word Processing Policy (Exams) 2024/25

Date October 2024 Review date October 2025

Key staff involved Role

SENCo

Exams Officer

IT manager

Contents
2 Introduction
2 Purpose of the policy
2 The use of a word processor
3 Exceptions 3 Arrangements at the time of the assessment for the use of a word processor
5 Appendix 1 The criteria Castle Rushen High School uses to award and allocate word processors
for examinations

2

Introduction
The use of a word processor in exams and assessments is an available access arrangement. At Castle Rushen High School the purpose of an access arrangement is to ensure, where possible, that barriers to assessment are removed for a candidate preventing him/her from being placed at a substantial disadvantage as a consequence of persistent and significant difficulties.
We apply the following principles to access arrangements:
• The purpose of an access arrangement is to ensure, where possible, that barriers to assessment are removed for a disabled candidate preventing him/her from being placed at a substantial disadvantage as a consequence of persistent and significant difficulties.
• The integrity of the assessment is maintained, whilst at the same time providing access to assessments for a disabled candidate. (AA 4.2.1) • A centre must make decisions on appropriate access arrangements for their candidates. Although professionals from other organisations may give advice, they cannot make the decision for the centre. They will not have a working knowledge of an individual candidate’s needs and how their difficulties impact in the classroom and/or in timed assessments. It is the responsibility of the SENCo to make appropriate and informed decisions based on the JCQ regulations. (AA 4.2.1)
• Although access arrangements are intended to allow access to assessments, they are not granted where they will compromise the assessment objectives of the specification in question. (AA 4.2.2)
• Candidates may not require the same access arrangements in each specification. Subjects and their methods of assessments may vary, leading to different demands of the candidate. SENCos must consider the need for access arrangements on a subject-by-subject basis. (AA 4.2.3) Purpose of the policy
This policy details how Castle Rushen High School complies with AA (chapter 4) ‘Managing the needs of candidates and principles for centres’ and (chapter 5.8) ‘Word processor' when awarding and allocating a candidate the use of word processor in his/her exams.
The term ‘word processor’ is used to describe for example, the use of a computer, laptop or tablet.

The use of a word processor
At Castle Rushen High School word processors are awarded on the following conditions:
• allocate the use of a word processor to a candidate with the spelling and grammar check facility/predictive text switched off where it is their normal way of working within the centre (AA 5.8.1)
• award the use of a word processor to a candidate if it is appropriate to their needs
Needs may include
3

  • A learning difficulty which has a substantial and long term adverse effect on his/her ability to write legibly
  • A medical condition
  • A physical disability
  • A sensory impairment
  • Planning and organisational problems when writing by hand
  • Poor handwriting
    • only permit the use of a word processor where the integrity of the assessment can be maintained (AA 4.2.1)
    • not grant the use of a word processor where it will compromise the assessment objectives of the specification in question (AA 4.2.2)
    • consider on a subject-by-subject basis if the candidate will need to use a word processor in each specification (AA 4.2.3)
    • consider the needs of the candidate at the start of the candidate’s course leading to a qualification based on evidence gathered that firmly establishes the candidates’ needs and ’normal way of working’ in the classroom, internal tests/exams, mock exams etc. and confirm arrangements in place before the candidate takes an exam or assessment (AA 4.2.4) • provide access to word processors to candidates in non-examination assessment components as standard practice unless prohibited by the specification (AA 5.8.2) Castle Rushen High School will not:
    • simply grant the use of a word processor to a candidate because he/she prefers to type rather than write or can work faster on a keyboard, or because he/she uses a laptop at home. Exceptions
    The only exceptions to the above where the use of a word processor would be considered for a candidate, would be: in the event of a • temporary injury or impairment, or a diagnosis of a disability or manifestation of an impairment relating to an existing disability arising after the start of the course (AA 4.2.4)

Arrangements at the time of the assessment for the use of a word processor
A candidate using a word processor is accommodated:
• In a suitable room in compliance with the regulations, Castle Rushen High School:
• provides a word processor with the spelling and grammar check facility/predictive text disabled (switched off) unless an awarding body’s specification says otherwise (ICE 14.20) • ensures the candidate is reminded to ensure that his/her centre number, candidate number and the unit/component code appear on each page as a header or footer e.g. 12345/8001 – 6391/01 (ICE 14.22)
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• The candidate is supervised throughout this process to ensure that he/she is solely performing this task and not re-reading their answers or amending their work in any way. • ensures the candidate understands that each page of the typed script must be numbered, e.g. page 1 of 6 (I

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