By Jonny Wathen | TransforMATive

The latest Tes article by Cerys Turner highlights a growing challenge for multi-academy trusts: the increasing volume, complexity and cost of responding to Subject Access Requests (SARs).

The figures are significant. Outwood Grange Academies Trust reports spending approximately £100,000 a year managing requests, while Wellspring Academy Trust describes how a single SAR can involve up to ten members of staff.

These demands place considerable pressure on already stretched education resources.

Importantly, trusts such as Wellspring have invested over several years in developing dedicated information governance capacity, organisational expertise, training and technology. Their experience demonstrates that even trusts with established arrangements are facing increasing pressures.

Others are at different stages of this journey, often managing complex information governance responsibilities alongside competing operational priorities.

For me, the response requires more than additional capacity. It demands a wider conversation about the maturity of information governance across the sector, the effectiveness of existing processes, the role technology can play and the support trusts should reasonably expect from government and regulators.

The challenge is not whether individuals should have access to their personal information. That right is fundamental. The question is how we deliver it effectively, proportionately and sustainably.

1. Effective information governance is built over time

Information governance is sometimes viewed primarily as a compliance function, with responsibilities delegated to a Data Protection Officer or another designated colleague.

In reality, effective information governance requires much more than an individual with specialist knowledge.

It depends on clear accountability, effective policies, established processes, appropriate systems and an organisational culture in which people understand their responsibilities.

Trusts with mature information governance arrangements have typically invested considerable time and resources in establishing these foundations. Other organisations may still be developing the capacity, skills and systems required to achieve the same level of consistency.

Neither position removes the increasing demands associated with SARs, but organisational maturity can make a significant difference to how effectively those demands are managed.

A mature information governance function does more than respond to requests. It equips the organisation to manage information consistently, proportionately and effectively.

One important observation from the Tes article is that some schools may be undertaking considerably more work than the law requires.

This is a wider sector concern, rather than a judgement on any individual trust. It highlights the importance of understanding both the obligations imposed by legislation and the practical boundaries of those obligations.

Knowing what an organisation is required to do and what it is not required to do, is an essential part of effective governance.

2. Responding to SARs requires a whole-organisation approach

A complex SAR rarely sits neatly within one department or professional discipline.

Information may be held across safeguarding systems, management information systems, HR records, emails, shared drives, pastoral records and other platforms.

Responding appropriately can, therefore, require coordinated input from school leaders, safeguarding professionals, HR teams, IT colleagues, administrators and information governance specialists.

Even the most experienced Data Protection Officer cannot manage this effectively in isolation.

Staff need appropriate training to understand how to identify relevant information, recognise sensitive personal data, preserve records, undertake proportionate searches and escalate decisions requiring specialist judgement.

There must also be clarity about who coordinates the response, who undertakes searches, who reviews information and who ultimately authorises disclosure.

The capability of the organisation is just as important as the expertise of the individual responsible for compliance.

This is why investment in training, shared understanding and established workflows should be viewed as essential organisational development rather than simply an additional compliance cost.

3. The public cost requires a coordinated response

Perhaps one of the most important considerations is the financial impact of responding to increasing volumes of SARs.

When an academy trust spends tens or even hundreds of thousands of pounds managing requests, that represents public money and staff capacity that cannot simultaneously be directed towards teaching, pastoral support or wider educational provision.

Of course, meeting statutory information rights is itself a legitimate and necessary use of public resources. The concern is the extent to which inefficient processes, uncertainty and avoidable administrative work increase that cost.

I would encourage both the Department for Education (DfE) and the Information Commissioner’s Office (ICO) to consider these wider implications when developing guidance, policy and expectations for the sector.

The ICO already provides guidance on reasonable and proportionate searches, clarification and the circumstances in which requests may be considered excessive or manifestly unfounded.

However, the experiences highlighted by Tes suggest that translating this guidance into consistent operational practice remains challenging.

School trusts need practical, education-specific examples addressing the complexity of SEND and safeguarding records, multiple information systems, large volumes of correspondence, third-party information and requests that span several years.

There is also a need for greater clarity about how organisations should respond to repeated requests and the specific circumstances in which the legal thresholds for refusal may be met.

The right of access must be protected, but trusts should not be left to interpret complex operational questions independently, potentially duplicating effort and incurring unnecessary cost.

Clearer guidance, practical resources and greater consistency could make a meaningful difference to the public cost of compliance.

4. Prevention should be part of the strategy

Much of the current conversation focuses on how schools can respond to SARs more efficiently.

That is important, but I think we should also consider how better information management could reduce the amount of unnecessary work involved before a request is ever received.

Data minimisation and effective retention practices are particularly relevant.

Most trusts have published retention schedules, but how consistently are these being implemented across every school, department and information system?

Are records being appropriately reviewed and deleted in accordance with established policies and legal requirements? Is unnecessary legacy information accumulating in shared drives, email accounts and disconnected systems?

The more information an organisation retains unnecessarily, the greater the potential burden when it must identify, search and review records. There is also a direct correlation with the growing cyber threats also experienced across the sector and beyond.

Importantly, this is about proactive, lawful information management, not deleting information in response to an existing request or circumventing disclosure obligations.

EdTech suppliers also have an important responsibility here.

Schools should not have to rely on manual workarounds to implement basic retention and deletion policies. MIS providers and other technology vendors should make it easier for trusts to apply retention schedules, manage access permissions and maintain appropriate information throughout its lifecycle.

Some suppliers have already begun improving these capabilities, but I would argue that effective information lifecycle management should increasingly become an expected feature of education technology.

5. Make appropriate information available by default

Another opportunity is to consider whether individuals need to make formal requests to obtain information that could reasonably be made available through existing channels.

Parents, carers and learners increasingly interact with schools through secure portals, apps and other digital platforms.

Could some of the information routinely requested through SARs be made available more easily through these systems?

For example, appropriate learner records, contact information and other routinely accessible information could be presented through secure platforms, subject to relevant legal rights, safeguarding considerations and access permissions.

Regular opportunities to review and correct information could also improve data quality and reduce misunderstandings.

This is not a substitute for the statutory right of access, nor should it create barriers to exercising that right.

However, making appropriate information readily available can reduce avoidable administration while improving transparency and strengthening relationships with families.

It is a relatively simple example of how better information management and purposeful digital design can benefit both the organisation and the individuals it serves.

6. Relationships, communication and clarification matter

We should also acknowledge that SARs are sometimes submitted alongside complaints, disputes or concerns about an individual’s experience of a school.

In these circumstances, the underlying issue may extend beyond the information being requested.

This makes the quality of communication and relationships particularly important.

Clear explanations, accessible information and constructive engagement can sometimes prevent misunderstandings from escalating.

The growing use of generative AI adds another dimension.

AI tools make it considerably easier to produce lengthy, detailed requests containing extensive references to legislation and broad demands for information.

That does not make a request invalid or imply that the individual has acted unreasonably. However, it can sometimes create a gap between the wording of a request and the information the person is actually seeking.

Where clarification is reasonably required, a constructive conversation may help identify the information sought and enable a more focused, effective response.

Such conversations must never be used to discourage legitimate requests or impose unnecessary barriers. They should be conducted within the applicable legal requirements and with respect for the individual’s rights.

There is a wider lesson here.

Good information governance is not solely about policies and processes. It is also about communication, transparency, trust and professional judgement.

7. Technology should reduce the burden without replacing professional judgement

Technology has an increasingly important role in supporting information governance, particularly where processes involve large volumes of repetitive administrative work.

Redaction is a clear example.

Anyone who has been involved in responding to a complex SAR will recognise the considerable time required to review documents, identify personal information, protect third-party identities and prepare records for disclosure.

These tasks are necessary, but elements of the work can be extremely resource-intensive when undertaken manually.

This is precisely the type of challenge we have been exploring at TransforMATive.

Our Eclipse platform has been designed specifically for education to support organisations with AI-assisted redaction.

Using machine learning and AI, Eclipse helps identify personal and potentially sensitive information, including contextual relationships that may require further review, allowing staff to complete redaction workflows more efficiently.

Importantly, Eclipse retains the human in the loop.

The technology supports the identification and redaction process, while authorised professionals retain responsibility for reviewing the information and deciding what should be disclosed, what should be protected and whether the final output is appropriate.

This distinction is essential when processing safeguarding information, sensitive educational records and personal information relating to children and families.

Eclipse is now used by more than 300 schools across England, reflecting growing interest in practical technologies that can reduce administrative workload while retaining appropriate professional oversight.

However, technology should not be viewed as a substitute for good governance, clear processes or trained colleagues.

The objective is to automate appropriate tasks, not automate accountability.

8. A sustainable response requires collective action

The increasing volume and complexity of SARs is not a challenge that individual schools and trusts should be expected to address entirely in isolation.

There are responsibilities across the education system.

• Trust leaders and governing boards should ensure that information governance arrangements are appropriately resourced, proportionate and regularly reviewed.
• Information governance professionals should be supported through training, consistent processes and access to specialist advice.
• The DfE and ICO should work together to provide clearer education-specific guidance and practical resources, recognising the operational and financial implications for schools.
• EdTech suppliers should help organisations manage information throughout its lifecycle, including access, retention, deletion and appropriate automation.
• The wider sector should share emerging practice, lessons learned and opportunities for greater consistency, rather than every trust independently developing solutions to the same problems.

For me, the strongest approach brings together governance, prevention, people, practice and technology.

Each has an important role, but none is sufficient in isolation.

A practical next step for trusts

For trusts currently experiencing increasing demand, I would encourage a review of the complete SAR process rather than simply adding more capacity to existing arrangements.

Some useful questions to consider include:

• Where are the greatest bottlenecks and administrative pressures?
• Do colleagues across the organisation understand their responsibilities?
• Are searches and reviews being conducted proportionately?
• Are published retention schedules being implemented in practice?
• Could appropriate information be made available more routinely?
• Are there opportunities to improve communication and clarification?
• Which repetitive activities could be supported more effectively through technology?
• Where would clearer guidance or specialist support make the greatest difference?

For those exploring AI-assisted redaction, Eclipse is available to trial free of charge, providing an opportunity to evaluate how technology could support existing information governance processes without making an immediate investment.

Explore Eclipse and start a free trial →

Ultimately, the objective should not be to make it more difficult for individuals to exercise their information rights, nor should it be to remove people from important decisions.

It should be to establish better processes, reduce unnecessary administrative work, protect sensitive information and ensure that valuable education resources are used as effectively as possible.

The increasing demand for SARs should prompt an important conversation about the expectations we place on schools, the resources available to meet those expectations and the opportunities to work more intelligently across the sector.

Good governance provides the foundations. Prevention reduces avoidable demand. Skilled people make the decisions. Technology helps make the process sustainable.

And as demand continues to grow, bringing these elements together has never been more important.

These same principles of accountability, purposeful innovation and human oversight are also central to Governing AI in school trusts, the guidance I recently co-authored with Samira Sadeghi for the Confederation of School Trusts (CST), in association with TransforMATive, which explores how trust leaders can govern AI responsibly while ensuring technology serves educational purpose and public benefit.

As part of the preparation for TransforMATive LIVE: Sweden, our leadership exchange taking place in December, I recently had the opportunity to spend a few hours in Stockholm.

Sweden feels like a particularly relevant place for this conversation. It has a long history of digitalisation in education, strong digital infrastructure and skills, and a well-developed EdTech ecosystem. Around nine in ten secondary pupils have access to a school-provided digital device, while the European Commission continues to describe Sweden as having a strong digital ecosystem, high-quality connectivity and a highly digitally skilled population. Digital Strategy

For me, that makes Sweden interesting not simply because technology is present, but because it provides an opportunity to explore what happens after digital adoption. How do digitally mature organisations make better choices about what technology should enable, where it should sit and, increasingly, where it should not?

That question stayed with me as I experienced Stockholm.

From the Vasa Museum and Djurgården, across the waterfront and Skeppsholmen, through to the Royal Palace and the streets of Gamla Stan, what struck me was the contrast.

The Vasa itself provides an extraordinary leadership lesson. It was an ambitious seventeenth-century Swedish warship which sank in Stockholm harbour just minutes into its maiden voyage in 1628, before being recovered from the seabed 333 years later. Vasa Museum

For me, its story is a reminder that progress is not simply about ambition, resources or technical capability.

It is also about judgement.

Challenge.

And whether an organisation creates the conditions for good decisions to be made.

Elsewhere, Stockholm brings together history, culture, design and modern public life in a way that feels intentional and connected rather than hurried.

That feels increasingly relevant to leadership in the age of AI.

AI gives us the ability to move faster, process more information and automate increasing amounts of work.

But speed and productivity are not the same thing as progress.

If every efficiency simply creates capacity for another report, another task, another analysis or another decision, we risk replacing workload with work intensity.

For MAT leaders, that distinction matters.

The promise of digital transformation should not simply be that we can fit more into the working day.

It should be that we can make better decisions about what deserves our time in the first place.

That is why I increasingly think head space is becoming a strategic resource.

Leaders need space to think.

Space to challenge assumptions.

Space to make connections between things that might otherwise remain separate.

Space to listen to different perspectives.

And, occasionally, space to decide that something does not need to be done at all.

This thinking sits at the heart of the Connect theme for our Digital Leadership Summit and our wider TransforMATive community, including TransforMATive LIVE.

Connect is not simply about bringing people together.

It is about creating the conditions for reflection, challenge and shared understanding.

It is about stepping outside the rhythm of everyday operational leadership long enough to ask whether we are solving the right problems, whether technology is genuinely helping and whether activity remains connected to organisational purpose.

These moments deliberately introduce a little useful friction.

They allow us to listen.

To compare experiences.

To question what has become normal.

To understand how other organisations are approaching similar challenges.

And to consider where technology can genuinely add value, rather than simply add pace.

For me, that leaves three increasingly important questions for MAT leaders:

What can technology enable us to do?

But also:

What should we do differently because the technology now exists?

And perhaps most importantly:

What should remain fundamentally human?

As trusts mature digitally, those questions become more important, not less.

The greatest value technology creates may not always be additional capacity to do more.

Sometimes it is the space to think more clearly about what matters, what we can stop doing and what should come next.

Perhaps that is one of the most important forms of Connect of all.

Jonny Wathen
CEO, TransforMATive

TransforMATive Insights brings together learning from our work with multi-academy trusts, sector leaders and partners, informed by the latest research and emerging evidence, to explore the issues, opportunities and practical choices shaping digital leadership across education.

Most conversations about operating models begin with structure.

Who reports to whom? What sits centrally? What remains within schools? Where does responsibility ultimately sit?

Those questions matter. But increasingly, I think some of the more important organisational challenges sit between the boxes.

Take AI governance.

A trust can appoint a senior responsible officer, publish an AI policy and establish a clear approval process.

Structurally, everything can look sensible.

But what happens when a teacher identifies a new use case?

When should the DPO become involved?

When does curriculum leadership need to engage?

Who speaks to procurement?

How does learning from one school reach another?

And what happens when an issue crosses technology, safeguarding, education, data protection and finance at the same time?

The answer rarely sits neatly within a single role or reporting line.

That is relational architecture.

It is the way people, teams and responsibilities connect around the work that actually needs to happen.

This feels particularly relevant to our Connect theme for this year’s Digital Leadership Summit.

As trusts grow and become more digitally mature, the challenge is not simply to design clearer structures. It is to ensure that the relationships between those structures are equally deliberate.

Evidence around organisational decision making consistently suggests that allocating roles and responsibilities is only part of the answer. Effective organisations also need clarity about how those roles interact, where information moves, who needs to be involved and how disagreement is resolved.

The same is true of organisational networks. Performance is shaped not only by formal hierarchy, but by the connections that allow knowledge, challenge and expertise to move across traditional boundaries.

For MAT leaders, that creates another set of questions.

Who needs to connect with whom?

About what?

How frequently?

What information should move between them?

Where does a decision ultimately sit?

And what happens when there is legitimate disagreement?

These questions become even more important in a trust model, where local agency and organisational coherence will always need to coexist.

The ambition should not be to centralise every decision or create another layer of process.

It should be to design the connections that allow the right decisions to be made, by the right people, with the right information.

That is why Connect is not simply about collaboration.

It is about organisational design.

It is about recognising that the quality of a trust’s operating model is shaped as much by the relationships between functions, schools and leaders as it is by the structures themselves.

So the provocation I would offer MAT leaders is simple:

If you removed every box from your organisational chart and left only the connections between them, would there still be an operating model?

If not, we may have designed the organisation, but not yet designed how it actually works.

Jonny Wathen
CEO, TransforMATive

TransforMATive Insights brings together learning from our work with multi-academy trusts, sector leaders and partners, informed by the latest research and emerging evidence, to explore the issues, opportunities and practical choices shaping digital leadership across education.

We can describe a multi-academy trust very neatly.

There is an executive team. Central functions. Regional structures. Schools. Committees. Reporting lines and accountability.

But that is not necessarily how the organisation actually works.

Knowledge rarely moves only through formal structures. Advice, influence, challenge and problem solving often travel through relationships that sit alongside the organisation chart. Some are visible. Many are not.

That matters.

Research into social networks has consistently shown the importance of connections between people who would otherwise sit in separate groups. It also highlights the value of individuals who bridge gaps between different networks, helping information, knowledge and opportunity move across organisational boundaries.

Applied to a multi-academy trust, the implications are significant.

Two headteachers might occupy exactly the same position on an organisational chart, with the same reporting relationship and broadly similar responsibilities.

But their experience of the organisation can be completely different.

One may speak regularly with five other heads, have strong relationships with colleagues in the central team, know who to contact when something goes wrong and feel confident asking for advice.

Another may primarily interact with their own school and formal line manager.

Structurally, they are identical. Relationally, they are very different.

As trusts grow, I think one of the most valuable leadership exercises is therefore to understand the network that actually exists.

Where does advice really come from?

Who do colleagues contact when they need help rather than when the process tells them to?

Who connects education with technology, finance with operations, or schools with the central team?

Where is important knowledge repeatedly held by one individual?

And which colleagues have quietly become critical points of organisational dependency simply because they are trusted, connected and know how things really work?

This becomes particularly important as trusts mature digitally.

Technology can make communication easier and information more accessible, but it does not automatically create meaningful connection. In fact, more platforms, more channels and more information can just as easily create additional noise.

The objective should not be maximum connectivity.

It should be purposeful connectivity.

For our Digital Leadership Summit, that is what makes Connect much more than an invitation to network.

Connect is an organisational design challenge.

It is about understanding how knowledge, trust and influence move through the trust. It is about ensuring that expertise is not trapped within individual schools, teams or roles. And it is about creating deliberate connections between the people responsible for education, operations, finance, people, data and technology.

Digital maturity increasingly depends upon this.

A trust can have excellent systems and still struggle if the relationships between those systems, teams and decisions are weak. Equally, strong networks can help organisations adapt more quickly, share practice more effectively and make better use of the expertise that already exists within them.

Perhaps the most useful question is this:

If we removed every formal reporting line from the organisation chart and instead mapped where knowledge, trust and influence actually flowed, what would our organisation look like?

And, more importantly, is that the organisation we intended to build?

Jonny Wathen
CEO, TransforMATive

TransforMATive Insights brings together learning from our work with multi-academy trusts, sector leaders and partners, informed by the latest research and emerging evidence, to explore the issues, opportunities and practical choices shaping digital leadership across education.

Connect Before You Automate

For several years, one of the promises of digital transformation has been that technology will give us time back.

AI makes that promise feel more achievable than ever. Reports can be drafted in minutes. Information can be synthesised almost instantly. Analysis that once required hours can happen before the next meeting begins.

But for leaders, there is a more important question:

What happens to the time we save?

Across our work with multi-academy trusts, we are increasingly seeing a tension between efficiency and intensity. When technology makes something quicker, the natural response can be to do more of it. Another report. Another scenario. Another analysis. Another meeting.

The risk is that we use technology to accelerate an operating model that was already too busy.

Efficiency can very quickly become intensity.

This matters because digital leadership is not simply about introducing better tools. It is about creating the organisational conditions in which technology genuinely improves the experience of pupils, staff and communities.

If AI reduces the production of a board report from three hours to thirty minutes, do we consciously return some of that capacity to colleagues? Do we create space for professional judgement, relationships and reflection? Or do we simply commission more activity because the capacity now exists?

That is why the theme of this year’s TransforMATive Digital Leadership Summit begins with Connect, before we move to Enable and ultimately Lead.

Connect is about more than technology.

It is about connecting digital investment to organisational purpose. Connecting strategy to the realities of delivery. Connecting leaders across education, operations, finance, people, data and technology. And, increasingly, connecting trusts with one another so that learning, challenge and innovation can be shared across the system.

Before we automate a process, we should ask whether the process still needs to exist.

Before we introduce another platform, we should understand the problem we are trying to solve.

Before we use AI to increase capacity, we should decide deliberately what we want to do with the capacity it creates.

And before we pursue the next technology opportunity, we should be clear about what should remain distinctly human.

For MAT leaders, the opportunity is not simply to make an already busy organisation move faster.

It is to redesign the organisation around what matters.

That requires connection first.

TransforMATive Insights draws upon our ongoing work with multi-academy trusts, sector leaders and partners, alongside the latest research and emerging evidence, to identify the themes, challenges and opportunities shaping digital leadership across education.

One of the privileges of preparing for TransforMATive LIVE: Sweden has been the opportunity to spend time in Stockholm, visit schools, speak with education leaders and begin to understand the system from the inside rather than from a distance.

What struck me most was not any single policy, technology or classroom practice. It was the value of stepping outside our own context.

In England, it is very easy to become absorbed by the immediate pressures of the system: accountability, attendance, funding, recruitment, workload, digital strategy and the pace of AI adoption. Those challenges are real, but they can also narrow our field of vision.

Being in Stockholm created a different kind of space.

Conversations with Swedish education leaders offered a perspective shaped by a different culture, policy environment and relationship with technology. Engaging with superintendents from the United States added another dimension again: different governance, different terminology, different constraints, but often remarkably familiar questions about pupils, teachers, leadership and the role technology should play.

That is where curiosity becomes powerful.

The value of international exchange is not in searching for a model that can simply be imported into another system. Context matters too much for that. The real value comes from asking better questions.

Why do you do it that way?

What problem were you trying to solve?

What has worked?

What has not?

What would you change if you were starting again?

And, perhaps most importantly: what assumptions in our own system have we stopped noticing because they feel normal to us?

That same mindset matters in the age of AI.

Technology can increasingly provide us with answers at extraordinary speed. It can summarise, analyse, recommend and generate. But leadership still requires the curiosity to interrogate those answers, seek alternative perspectives and understand the context behind them.

There is a risk that greater access to information makes us less inclined to explore.

For me, experiences like TransforMATive LIVE: Sweden are a deliberate counterbalance to that.

They create space to observe schools directly, hear from people working in different systems, compare perspectives and return to our own organisations with new questions rather than borrowed solutions.

To Connect is not simply to meet more people. It is to expose ourselves to perspectives that challenge our own, to make connections between ideas and to remain curious enough to reconsider what we think we already know.

The most valuable outcome of an international leadership exchange is therefore unlikely to be a list of things to replicate.

It is the moment when somebody else’s experience causes you to look at your own organisation differently.

And sometimes that question, rather than the answer, is where transformation begins.

The current debate around devolution, technical education, accountability and funding points to a wider challenge for school trusts.

How do we build organisations that can continue to deliver purposeful outcomes when policy, structures and expectations continue to change?

Governments will change. Policy will change. Funding models will change.

The purpose of a school trust should not.

Our role is to create the conditions in which children, communities and the people who serve them can thrive.

That means the next phase of digital transformation cannot simply be about infrastructure, devices, systems or standalone AI tools. It has to be about the operating model.

From digital strategy to an AI-enabled operating model

Over the past decade, much of the digital transformation agenda has rightly focused on infrastructure, cloud platforms, cyber security, devices and data.

Those foundations remain essential.

The opportunity now is to think more fundamentally about how work gets done across a trust.

An AI-enabled trust should not be a traditional organisation with an AI product layered over the top.

It should be an organisation designed around better information flow, clearer decision making, reduced duplication and stronger organisational intelligence.

Finance, HR, education, estates, governance and IT should not operate as disconnected functions linked together by spreadsheets and meetings.

The goal should be a more connected operating model where leaders can access the information they need, routine work is simplified or automated, and people have more capacity to focus on the work that requires judgement, relationships and leadership.

The outcome is not fewer people.

It is better use of people’s time.

People

Technology should enable people.

Across school trusts, talented leaders and teams still spend too much time moving information between systems, reconciling spreadsheets, producing reports and completing repetitive administrative processes.

That is an operating model problem.

The starting point should be the work.

What decisions need to be made?

What information is required?

Which activities genuinely need professional judgement?

Which processes exist because systems do not connect effectively?

AI and automation should be used where they reduce friction and release capacity.

They should not replace the human contribution that matters most.

Judgement, creativity, empathy, relationships and leadership remain central to how successful trusts operate.

Place

Place matters.

A rural trust in Lincolnshire will operate in a very different context from a large urban trust in Greater Manchester.

A trust working across several local authorities may experience different approaches to SEND, funding, employer engagement, transport and public services.

That difference should be recognised.

It should not, however, lead to fragmentation.

Trusts should not have to choose between complete centralisation and complete localisation.

A mature operating model can establish common standards for data, identity, cyber security, platforms and governance while still allowing schools and communities to respond to their own context.

There is a simple principle here.

Standardise what should be common. Contextualise what should be different.

Technology can make that balance easier to achieve.

Partnership

The same applies beyond the boundaries of the trust.

If school trusts are expected to act as civic institutions, our operating models need to support genuine partnership.

Education does not sit separately from health, employment, housing, transport, universities, local authorities or employers.

This becomes particularly important when we consider young people who are not in education, employment or training.

Schools can provide excellent education and strong qualifications.

But education cannot create jobs.

If routes into employment are limited, or young people cannot access the opportunities available to them, schools cannot solve that challenge alone.

This is where partnership matters.

Trusts, colleges, universities, employers, local authorities and wider public services need better ways to share insight, understand need and coordinate action.

Technology should help make that easier.

It should support a shift from disconnected systems of record towards better connected systems of intelligence.

Local relevance without local limitation

There is an important distinction to make.

Local employer engagement matters, but vocational education cannot be shaped solely by immediate local labour market needs.

Young people need to be prepared for a much wider economy.

That means developing transferable knowledge and skills, digital capability, adaptability and the confidence to move between sectors, places and opportunities.

The jobs available locally today may not be the jobs available in ten years.

The same principle should apply to how trusts design their operating models.

They should respond to place without becoming constrained by place.

Purpose before politics

Education operates within a political environment.

Different governments will have different priorities, different policies and different views about how public services should work.

Trusts need to be capable of responding to that change without constantly redesigning the organisation around the latest policy announcement.

That requires organisational capability.

Strong governance.

Clear data.

Secure and interoperable systems.

Distributed leadership.

Trusted partnerships.

Responsible use of AI and automation.

These are not political positions.

They are the foundations of a resilient organisation.

A strong operating model should allow a trust to absorb change without destabilising the organisation responsible for delivering it.

The opportunity for school trusts

The future trust operating model should be more connected.

People connected to information.

Schools connected to communities.

Trusts connected to partners.

Leaders connected to the insight they need to make better decisions.

Technology should sit underneath that model, enabling it rather than defining it.

AI has a role to play, but it is not the strategy.

The strategy is to build organisations that are more connected, more responsive and better able to turn information into action.

Digital transformation should therefore be judged by more than whether systems have been modernised.

It should be judged by whether the organisation is better able to deliver purposeful outcomes through people, place and partnership, regardless of the politics of the day.

At the recent CST Data and Digital Transformation Conference, I had the privilege of chairing a discussion with Ather Abbas, Director of Strategy and Transformation at E-ACT, and Tricia Slater, COO at Empower Multi-Academy Trust, exploring a challenge that will be familiar to almost every trust leader: how do we deliver meaningful, sustainable transformation when ambition exceeds the capacity and funding available to us?

A key takeaway for me was that, despite E-ACT and Empower operating at very different scales, many of the fundamentals of successful transformation were remarkably consistent.

The discussion reinforced something I have seen repeatedly through our work with trusts at TransforMATive: transformation rarely fails because organisations lack ambition or ideas. The greater challenge is creating the organisational conditions that allow those ambitions to become reality.

Transformation has to start with people

One of the strongest messages from Ather’s contribution was that strategic transformation cannot simply become another technology programme.

E-ACT describes transformation as cross-functional, distinguishes it from business as usual, and places the creation of the right conditions for innovation at its heart. Perhaps most significantly, its thinking follows the sequence human behaviour > digital > data > AI, alongside an emphasis on collective intelligence and people.

That ordering matters.

It is tempting, particularly as AI develops at such pace, to begin conversations with platforms, tools and emerging technologies. But organisations do not transform because they have purchased better technology. They transform because people change how they work, collaborate, make decisions and solve problems.

Technology can enable that change. It cannot substitute for it.

For leaders, this means creating space for staff to understand why something is changing, contribute to how it develops and build the confidence required to adopt new practices.

Capacity is a strategic consideration, not an implementation problem

Tricia’s reflections from Empower brought this issue into particularly sharp focus.

As a smaller trust, Empower has had to make deliberate decisions about where to focus its resources. Its digital strategy runs from 2025 to 2030 and considers infrastructure, data, cyber security and innovation as part of a coherent approach rather than a series of isolated technology projects.

But having a strategy is only one part of the equation.

Empower explicitly recognises that limited organisational capacity requires initiatives to be prioritised and carefully phased, allowing progress without overextending the organisation.

This was perhaps my biggest reflection from the session.

We often talk about roadmaps in terms of what will happen and when. But a credible roadmap also needs to answer:

Who is going to deliver this, what capacity will they require, and what are we prepared to stop, delay or sequence differently to make it achievable?

Adding another programme to an already overloaded organisation isn’t transformation. In many cases, it simply creates another layer of pressure.

Capacity therefore needs to become part of the strategic conversation from the beginning rather than something we discover halfway through implementation.

Prioritisation doesn’t mean lowering ambition

One of the most useful examples from Empower was how it has approached investment.

The trust pooled Devolved Formula Capital funding to enable collective investment across its schools, making better use of the resources available to it. It also chose to prioritise high-quality devices for teachers before progressing further with student-facing technology.

There is an important principle here.

Transformation doesn’t always require doing more. Often it requires being clearer about what needs to happen first.

Getting the foundations right may feel less exciting than introducing the newest platform or innovation, but infrastructure, security, devices, skills, governance and data capability determine whether the next stage of transformation will succeed.

Good sequencing creates momentum.

Build change with the organisation, not to the organisation

Empower’s approach to digital champions was another example that resonated with me. Rather than selecting technology specialists, the trust identified strong teachers to lead peer-to-peer change, helping create credibility and adoption amongst colleagues.

That reflects a much broader lesson about organisational change.

Transformation becomes sustainable when capability spreads beyond the central team responsible for initiating it.

Digital transformation therefore shouldn’t create greater dependency on a small number of specialists. Done well, it should increase the confidence and capability of the wider organisation.

Empower similarly identifies active staff involvement, confidence-building and collaborative changes in practice as essential to cultural change.

That feels particularly important as trusts consider AI. The organisations that benefit most are unlikely to be those that simply provide access to the greatest number of AI tools. They will be those that develop the judgement, confidence and shared understanding required to use them effectively.

Governance has to connect ambition with reality

The final theme running through our discussion was governance.

Empower positions governance as central to oversight, accountability and ensuring that digital strategy remains aligned with wider organisational priorities.

For me, good governance should continually test the relationship between ambition, investment, capacity and impact.

Are we still solving the right problem?

Do we have sufficient capacity to deliver the next phase?

What evidence tells us the change is having the intended effect?

What have we learned that should influence the roadmap?

And, importantly, should something that appeared important twelve months ago still be a priority today?

A roadmap should provide direction without becoming a constraint. Sustainable transformation needs enough governance to maintain purpose and accountability, while retaining enough flexibility to respond to what the organisation learns along the way.

A reflection for autumn planning

The session reinforced that sustainable transformation is rarely about finding a single breakthrough technology or launching a huge programme of change.

It is about making deliberate choices.

Prioritising investment. Building strong foundations. Sequencing implementation. Creating organisational capacity. Engaging people. Developing capability. And ensuring governance continually connects activity back to organisational purpose.

Empower describes the challenge as balancing immediate operational requirements while building the foundations for scalable, pedagogy-first transformation. That balance is something every trust, regardless of size, has to navigate.

As leadership teams move into autumn planning, my reflection from the conversation is therefore a simple one:

A credible roadmap needs to explain not only what will change, but how the organisation will have the capacity to deliver it.

Because sustainable transformation isn’t measured by how much change we start.

It is measured by how much meaningful change we are actually able to embed.

Jonny Wathen, CEO of TransforMATive, said:

“Over the past four years, we have collaborated with CST and leaders across the education sector to deliver masterclass programmes in digital strategy, artificial intelligence, cyber security and privacy. We have also been proud to support CST’s CEO Network, Data and Digital Transformation Community and Annual Conference, bringing trust leaders together to share expertise, challenge thinking and learn from one another.

“Becoming a Platinum Partner formalises our strategic relationship and provides a strong foundation for the next chapter of our work together. We look forward to welcoming more CST members to our free-to-attend thought leadership events and showcasing how our products and services can help trusts address their priorities, improve efficiency and build lasting digital capability.”

We look forward to seeing you in person at the upcoming CST Annual Conference in Birmingham. Come and say hello to the TransforMATive team, share your trust’s priorities and explore how we can support your next steps.

Over the past few years, I’ve sat in countless conversations with trust leaders discussing digital transformation, AI, accountability, governance and school improvement. Whilst the headlines often focus on the latest technology or the next inspection framework, the reality is usually far more nuanced.

Recently, I had the privilege of joining a group of Multi-Academy Trust CEOs and senior leaders at the Red Kite Connect CEO Roundtable. The conversation covered everything from digital maturity and artificial intelligence to Ofsted reform, MAT inspection and trust assurance. My key takeaway wasn’t the diversity of topics, it was the consistency of the message.

Despite the pace of change, trust leaders are remarkably aligned on one thing:

Technology is not the starting point. Governance is.

Digital Transformation Isn’t Really About Technology

We often talk about digital transformation as though it’s a technology challenge. In reality, the most successful trusts aren’t defined by the software they buy or the AI tools they deploy. They’re defined by how clearly they govern them.

The trusts making the greatest progress are those with strong executive ownership, clear decision-making processes, robust information governance and a direct link between digital investment and organisational strategy. They understand that technology should serve the trust’s mission, not become a distraction from it.

Conversely, many of the challenges we encounter when working with trusts stem from fragmented decision-making, duplicated systems, underutilised software and a lack of visibility over what is actually being used across the organisation.

The lesson is simple: digital maturity starts with organisational maturity.

AI Is Exposing Existing Weaknesses

Artificial intelligence is accelerating a conversation that many trusts were already struggling to have.

Questions around data governance, supplier management, risk, compliance and accountability are no longer theoretical. AI is forcing leaders to revisit assumptions about how technology is adopted, monitored and governed.

What’s becoming increasingly clear is that AI governance cannot sit solely with ICT teams or Data Protection Officers. It requires leadership involvement, board oversight and organisational understanding. The trusts that thrive will be those that develop a balanced approach, encouraging innovation whilst maintaining appropriate safeguards.

The challenge isn’t whether AI will become part of education.

The challenge is whether our governance models are evolving quickly enough to manage it responsibly.

Accountability Is Changing

Alongside the digital conversation sits another significant shift: accountability.

Leaders around the table broadly accepted the principle that MATs should be accountable for decisions made at trust level. Given the strategic influence trusts now have over curriculum, workforce, finance, estates, inclusion and digital infrastructure, trust-level inspection feels like a logical next step.

Yet significant questions remain unanswered.

What exactly will MAT inspections evaluate? Organisational effectiveness? Educational outcomes? Governance? Financial stewardship? Improvement capacity?

Perhaps most importantly, how do we ensure that trusts serving the most challenging communities are evaluated fairly and contextually?

The strongest message from trust leaders was not resistance to accountability. It was a desire for accountability systems that recognise complexity, context and long-term improvement rather than reducing effectiveness to a set of performance metrics.

The Rise of Assurance

If there was one theme that connected every discussion, it was assurance.

As trusts continue to grow in scale and complexity, boards need greater confidence that strategy is being delivered, risks are understood and impact can be demonstrated.

Assurance is no longer just about compliance.

It’s becoming a strategic capability.

Educational assurance, governance assurance, digital assurance, cultural assurance and operational assurance are increasingly converging into a single organisational view. Trust boards want visibility. Executive teams need confidence. Stakeholders expect evidence. Future inspection frameworks will almost certainly demand it.

The trusts that are investing in integrated assurance models today are likely to be the ones best prepared for whatever comes next.

What This Means for Trust Leaders

The education sector is entering a period of profound change.

Digital transformation continues to accelerate. AI is reshaping expectations. Inspection frameworks are evolving. Accountability is moving upwards towards trust-level leadership. Boards are demanding greater assurance.

Yet the foundations remain remarkably consistent.

Strong governance.

Clear strategy.

Effective leadership.

Thoughtful use of technology.

Relentless focus on improving outcomes for children and young people.

The trusts that succeed won’t necessarily be those with the newest tools or the biggest budgets. They’ll be the organisations that create clarity amidst complexity and build systems capable of supporting sustainable improvement.

How We Can Help

At TransforMATive, these are exactly the conversations we’re having with trust leaders every day.

Whether you’re looking to strengthen Trust assurance, digital governance, review your software estate, develop an AI strategy, prepare for future inspection frameworks or simply create greater organisational clarity, we’d love to help.

The challenges facing MAT leaders are becoming increasingly interconnected. The solutions need to be as well.

If you’d like to explore how your trust can build stronger foundations for the future, get in touch with our team. We’d be delighted to share what we’re seeing across the sector and discuss how we can support your journey.

Because successful transformation doesn’t start with technology.

It starts with leadership.