Navigating the Redaction Divide: SAR or PEX?

Schools are increasingly required to manage sensitive information in ways that balance transparency, fairness, and data protection. One area that frequently creates confusion is the difference between redaction undertaken for a Subject Access Request (SAR) and redaction applied when preparing documentation for a Permanent Exclusion (PEX) Review Panel. The Redaction Guide for PEX Panels has been introduced to address this issue and provide clear, practical guidance for staff.

While both processes involve removing or obscuring personal information, the purpose and threshold for redaction differ significantly. 

The Key Difference Between SAR and PEX Redaction

• SAR redaction is primarily driven by data protection law. When responding to a Subject Access Request, organisations must provide individuals with their personal data while protecting the privacy of third parties. This often results in extensive redaction where another person's data appears in documents.

• PEX panel documentation, however, serves a decision-making function rather than a data disclosure one. The panel must determine whether:

• • the exclusion was lawful,
    
    

  • the decision was reasonable, and
    
    

  • correct procedures were followed.
    
    

Because of this, the threshold for redaction is different. Over-redaction can undermine the panel’s ability to understand events, assess proportionality, and review the decision-making process.

The Policy’s Core Principle

The guidance emphasises that redaction in a PEX context should focus on protecting irrelevant third-party personal data, not removing information that explains what happened. 

This distinction is critical because staff sometimes apply SAR-style redaction practices to PEX bundles, which can lead to excessive anonymisation and confusion for governors reviewing the case.

Practical Support for Schools

The policy has been designed as a working guide, helping staff confidently prepare panel documentation while remaining compliant with data protection principles. It provides practical direction on:

• What should be redacted, such as the names of unrelated pupils or personal contact details.
  
  

• What must remain visible, including timelines, factual descriptions of incidents, staff roles, and policy references relied upon in the exclusion decision.
  
  

• How to anonymise clearly, for example by using consistent labels such as [Pupil B] or [Witness 2] rather than heavy black redaction blocks.
  
  

• Handling evidence such as CCTV, ensuring third parties are anonymised while the key incident remains visible.
  
  

Promoting Fair and Transparent Panel Processes

Ultimately, the guide aims to reduce uncertainty for staff while supporting fair, well-informed panel decisions. By distinguishing clearly between SAR and PEX redaction practices, the policy ensures that privacy is protected without compromising the panel’s ability to properly review the circumstances of a permanent exclusion.

In doing so, it reinforces an important principle: redaction should protect personal data, but it should never obscure the facts needed to understand what happened.

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