The Ofsted complaints procedure has also been heavily criticised for opacity and a strong bias in favour of the inspectors. Geoff Barton, after writing an article strongly critical of Ofsted's use of raw data rather than inspection reports to determine grades, noted that: "the Ofsted complaints procedure too often seems constructed around a deep and dutiful need for self-protection. Thus an inspection system that demands transparency from schools refuses to release its own inspection notes, When challenged, it dares us to resort to a Freedom of Information request and then rejects those same requests because they don’t conform to a definition of “public interest”.