EdCon2026: Managing school complaints and data requests in the AI era

Schools are increasingly navigating a new and complex landscape when it comes to managing complaints and data requests in the AI era.

In our latest EdCon2026 session, Vicky Hatton, Partner in our education team, and Claire Archibald, Legal Director and AI governance specialist, explore the reality of AI-driven parental complaints and how schools can deal with them effectively through a clear, strategic framework. 

The new reality: AI-driven parental complaints

The session revealed a striking picture of what school leaders are already experiencing on the front line. 50% of attendees reported a significant increase in complaints from parents that appear to have been drafted or enhanced using AI tools in the last 12 months, with many others reported seeing at least some form of increase. 

The impact of this shift is being felt acutely, with 77% of respondents noting that AI-generated or AI-enhanced complaints had a more formal or legalistic tone, requiring additional time to respond, while 72% reported an increase in the length and complexity of complaints.

The white paper: Complaints 

The UK Government’s white paper, ‘Every child achieving and thriving’, proposes the following on complaints:

• A new digital solution with a single accessible platform to simplify the complaints process, improve coordination between bodies, improve data collection, and prevent parallel escalation. 
• Clear timeframes, with new mutual expectations and consistent deadlines for resolving complaints.
• Updated guidance on vexatious complaints, including case studies and clarity on which national body is best placed for specific complaints.
• A new Parent's Guide developed with ParentKind and IET to help parents resolve issues at the earliest point before they become a formal complaint.
• A consultation on requiring maintained schools to include an independent member on complaints panels to improve fairness and objectivity.

The white paper does not, however, provide a root-and-branch review of school complaints. The new Parent's Guide is premised on all parties acting reasonably, which is not always reflected in reality. On the positive side, it does give schools an opportunity to open a conversation with parents about how to raise complaints appropriately, and schools can use it as a prompt to review their own processes and provide training where needed.

The white paper: Data and AI

On data and AI specifically, the white paper touches on:

• Data sharing through collaboration but is light on details about the framework schools actually need to ensure this is done in a way that meets data protection legislation requirements as well as parental expectations. 
• EdTech accountability: The DfE signals that the burden should shift from schools to the wider system - schools should be consumers of a well-regulated marketplace, not its quality controllers. 
• Commitment to developing AI tutoring tools for secondary pupils by the end of 2027, but the data protection groundwork cannot wait until then. 
• Biometric data, such as AI eye-gaze software, which raises particular concerns, so clear communication with parents will be essential.

The white paper does not cover a national data sharing framework, standardised DPIA templates or proactive communication with parents. Our summer 2025 School Leaders Survey showed that nearly two-thirds of school leaders are dissatisfied with the current policy landscape on complaints. Given the challenges schools are facing right now, it’s important that they take ownership and create their own complaints and data protection strategy.

The strategic framework: Three pillars

The session introduced a strategic framework built around three pillars: prevention, protection, and process. Schools that invest in upstream thinking - sound policy, training, and a culture of early resolution - deal with complaints and data requests best, and those with a strong framework in place will have better outcomes overall.

Pillar 1: Prevention

There is a counter-intuitive paradox at the heart of complaints management: helping parents raise concerns more effectively actually reduces the number of formal complaints. 

Complaints tend to escalate for three reasons: 

• The underlying issue is rarely as serious as it first appears.
• The initial concern was poorly articulated.
• The initial concern was badly handled.

Prevention strategies include:

• Providing clear, accessible, jargon-free complaints information for parents.
• Making early contact and acknowledgement without delay.
• Giving empathetic first responses that demonstrate the concern has been heard.
• Creating informal resolution pathways that are genuinely accessible and well-communicated.
• Maintaining regular communication with parents about school life to reduce information vacuums.

The same rings true for data requests, the best subject access request is one that is never made, so consider what can be done to remove the need for formal requests to be made at all. 

Pillar 2: Protection

Building AI literacy among staff is essential. This includes:

• Training staff to recognise indicators of AI-generated content.
• Not assuming that AI use means bad faith. Parents may be using AI because they are anxious, not adversarial.
• Recognise parents may not fully understand the content they have submitted.

When calling out AI use constructively, schools should:

• Adopt a non-confrontational, resolution-focused approach.
• Acknowledge the concerns raised rather than the format.
• Gently redirect towards dialogue.

Where a parent refuses to meet, schools should:

• Move to a focused, scoped written response.
• Identify the core concerns and respond to those.
• Set out clearly what the school has done or will do. 
• State what falls outside the scope of the complaints procedure.
• Invite dialogue again - but once, not repeatedly.

Schools are not required to: 

• Respond to every AI-generated demand as if it were a valid legal obligation.
• Produce documents or records on demand outside of a formal SAR or FOI process.
• Engage in open-ended written correspondence indefinitely.

Pillar 3: Process

The third pillar focuses on handling complaints effectively in practice, including investing in the informal stage, training staff on effective scoping, managing bombardment, and handling parallel information requests.

Being able to map these out clearly, rather than treating a situation as one undifferentiated complaint, is essential to managing it effectively.

Parents who feel they are treated fairly are less likely to return with further complaints. Investing in process, and in the people who manage it, is therefore not just a compliance exercise, but a meaningful contribution to a school's overall relationship with its parent community.

Likewise, having a robust and thorough process for data requests, ensuring they are properly managed when they are submitted, with evidenced audit trails of the process followed, means that any subsequent complaints are easier to handle and resolve. 

Key takeaways

The practical key takeaways that schools should be aware of include:

• AI is changing the nature of parental communication, schools need to prepare now, not when it happens.
• Early, empathetic intervention remains the most effective tool for preventing escalation.
• Respond to the substance of complaints and data requests, not to the format generated by AI.
• Build AI literacy among staff - recognise the signs and respond constructively.
• The Three Pillars, prevention, protection and process, provide a framework for both strategy and immediate response.
• Schools cannot afford to wait for central guidance, they must take ownership and develop their own complaints strategy.

We’re here to help. To discuss this topic further and your specific circumstances, please get in touch.