FOI Requests for University Grade Data: How It Works

GradeHack exists because the Freedom of Information Act 2000 makes it possible to ask UK universities for their module-level grade distribution data — and receive an actual answer.

This is not a loophole. It is a right. Here is how the process works.

What is the Freedom of Information Act?

The Freedom of Information Act 2000 (FOIA) gives anyone the right to request recorded information from public authorities in England, Wales, and Northern Ireland. Universities are public authorities under the Act — as are councils, government departments, NHS trusts, and a range of other bodies.

The Act means a university that holds historical pass rates for every module it has ever run cannot simply refuse to share that data without legal justification. It must either disclose the information or cite one of the Act's limited exemptions.

Scotland has equivalent legislation: the Freedom of Information (Scotland) Act 2002. The process is almost identical.

What grade data can you request?

You can request any recorded information a university holds. For grade distribution purposes, the most useful requests include:

• Module-level grade distributions: how many students in each cohort scored in each mark band, for a specific module and academic year
• Pass rates by module: the proportion of students who passed a specific module in a given year
• First-class rates by programme: the proportion of students graduating with a First from a specific course
• Degree outcome data by subject: aggregate classification outcomes broken down by programme

Not every university records this data in the same format. Some respond with broad bands (First, 2:1, 2:2, Third). Others provide more granular mark ranges (40–49%, 50–59%, 60–69%, 70%+). Both are useful. The granular version lets you see how far a module's distribution extends above the First-class threshold.

What universities can refuse to disclose

The FOIA includes exemptions that universities can invoke. The ones most commonly cited for grade data:

Section 40 (Personal data): if the requested data would identify individual students, it is exempt. This is why responsible public disclosures — including all GradeHack data — suppress results from cohorts smaller than ten students. A module with only six students in a given year cannot be disclosed without risking individual identification.

Section 43 (Commercial interests): occasionally a university argues that grade distribution data is commercially sensitive. This exemption is difficult to sustain for historical module data, and the Information Commissioner's Office has generally not upheld it in similar cases.

Cost limit: if responding to your request would exceed £450 in staff time (roughly 18 hours of work), the university can refuse on grounds of cost. A single precise request — "please provide the number of students achieving each grade band for module [code] in academic years 2019/20 to 2022/23" — is almost never refused on cost grounds. Vague requests covering dozens of modules across multiple years sometimes are.

How to file a request

The process is straightforward.

1. Identify the information you want as specifically as possible. Module code, academic year range, which grade bands or mark ranges you are asking for.

2. Send the request to the university's FOI team. Most universities publish an FOI officer email address on their website. You can also file via WhatDoTheyKnow, a platform that sends FOI requests on your behalf and publishes the correspondence publicly — which means the data becomes a public record.

3. Receive the response within 20 working days. If the university needs more time, they must notify you.

4. Appeal if necessary. If the university refuses, or redacts more than seems justified, you can request an internal review of the decision. If that fails, you can escalate to the Information Commissioner's Office (ICO), the independent regulator.

What the responses look like in practice

Some universities are thorough and respond quickly with detailed datasets. Others are slow, produce partial responses, or initially refuse and require an internal review before disclosing. A small number have argued that grade distributions represent personal data for entire module cohorts — an argument that does not hold up legally for cohorts of sufficient size.

Over 18 months of filing requests at UK institutions, the pattern is consistent: most universities comply eventually, and the data they disclose reveals far more variation in module-level outcomes than any public source acknowledges.

What that variation looks like is documented here.

The Exeter origin

GradeHack's data collection began at the University of Exeter in 2018. Module-level grade distributions for the Computer Science department — including ECM3428 and related modules — showed that students were making module choices with almost no information about how marks actually spread within those modules.

The variation was striking. Some modules in the same department, assessed at the same level, taught by broadly similar staff, produced very different distributions. One module might have 8% of students achieving a First in a given year. Another, structurally very similar, might have 35%.

That pattern was not an Exeter anomaly. As requests were filed at other institutions, the same structural variation appeared everywhere. The gap was not a quirk of one university — it was a sector-wide absence of publicly available module-level data.

Filing FOI requests is how that gap gets closed, institution by institution.

How GradeHack uses this data

GradeHack files requests systematically — by university, by department, for module cohorts of at least ten students — and aggregates the responses into a searchable dataset.

Every data point is traceable to an original FOI disclosure. The underlying requests are archived on WhatDoTheyKnow, which means the provenance of every figure is publicly verifiable. We do not publish raw numbers from cohorts smaller than ten, and we do not publish exact mark counts — only banded signals that indicate whether a module has an above-average, average, or below-average First rate.

If you want access to the module-level data GradeHack has collected, join the waitlist here.