Freedom of Information request: advertising for clearing

The request was refused by School of Oriental and African Studies.

Dear School of Oriental and African Studies,

Under the Freedom of Information Act, can you please tell me how much money you spent on advertising for clearing in 2019.

Can you please provide subtotals for the following categories (feel free to break them down further if that's appropriate):
1. Facebook
2. Instagram
3. Google - that is, search advertising
4. YouTube
5. Snapchat
6. Twitter
7. Other social networks (please specify)
8. Amazon
9. Online - that is, on websites excluding social networks, or those websites those listed above (this includes advertising using Google's ad network)
10. Television
11. National newspapers
12. Local newspapers
13. Magazines
14. Posters and billboards
15. Radio
16. Public transport billboards

Can you also provide an example of an ad in each of the above formats.

For the online forms of advertising, can you also tell me how many clicks each advertisement received. Can you also provide any other data you have which indicates the engagement with each ad.

For Google advertising, can you list which keywords you advertised against. Can you please indicate the cost-per-click in each case.

For Facebook, can you please supply
- A list of the interests and/or demographics you targeted
- If you used custom audiences, where you derived the data to make that custom audience from

Can you please provide this information in an Excel format.

Thanks for your help!

Yours faithfully,

Rowland Manthorpe

Information Compliance Manager, School of Oriental and African Studies

Dear Rowland Manthorpe,

Thank you for your request for information which has been received by
SOAS.

We will provide you with the School’s response as soon as possible and
within 20 working days of the date of your request.

Yours sincerely,

Chris Elliott

Records Management

-- 

Governance and Compliance Directorate
SOAS, University of London
Russell Square, London WC1H 0XG
[1][email address]   [2]http://www.soas.ac.uk/infocomp 

The world's leading institution for the study of Asia, Africa and the
Middle East

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Information Compliance Manager, School of Oriental and African Studies

FOI2019-185

 

Dear Rowland Manthorpe

 

Thank you for your Freedom of Information Act request of 7^th September
2019. I have reproduced your questions below together with SOAS’s
response.

 

Under the Freedom of Information Act, can you please tell me how much
money you spent on advertising for clearing in 2019.

Can you please provide subtotals for the following categories (feel free
to break them down further if that's appropriate):
1. Facebook
2. Instagram
3. Google - that is, search advertising
4. YouTube
5. Snapchat
6. Twitter
7. Other social networks (please specify)
8. Amazon
9. Online - that is, on websites excluding social networks, or those
websites those listed above (this includes advertising using Google's ad
network)
10. Television
11. National newspapers
12. Local newspapers
13. Magazines
14. Posters and billboards
15. Radio
16. Public transport billboards

Can you also provide an example of an ad in each of the above formats.

For the online forms of advertising, can you also tell me how many clicks
each advertisement received. Can you also provide any other data you have
which indicates the engagement with each ad.

For Google advertising, can you list which keywords you advertised
against. Can you please indicate the cost-per-click in each case.

For Facebook, can you please supply
- A list of the interests and/or demographics you targeted
- If you used custom audiences, where you derived the data to make that
custom audience from

Can you please provide this information in an Excel format.

Our Response

 

SOAS publishes its annual spend on Marketing and Student Recruitment in
its annual Financial Statements, next due for publication in November
2019. The statement will be published on the website here:
[1]https://www.soas.ac.uk/finance/accounts/

 

However the specific information requested has been
withheld under section 43(2) of the FOIA as we believe release of our
expenditure on individual campaigns for undergraduate and postgraduate
student recruitment and marketing would prejudice the commercial interests
of the School. The clearing market is extremely competitive and, if
disclosed, the requested information would be of use to our competitors
who could adjust their budgets and campaigns accordingly. This is likely
to result in the School having to raise their level of expenditure.
Consequently, disclosure of the information would directly result in harm
to the School’s financial and commercial position. SOAS has a
responsibility and a legitimate interest as a publicly funded body to seek
value for money in procuring services or facilities, and we therefore
consider that our specific interest in using public funds efficiently
outweighs the broader public interest in transparency and accountability.

 

Your right to appeal
I hope that you are satisfied with this response, but in the event that
you are not, you may request an internal review, by writing to me at the
following address within 40 working days of receipt of this response:

 

Information Compliance Manager

SOAS, University of London

Thornhaugh Street

Russell Square

London WC1H 0XG

United Kingdom

 

Email: [2][SOAS request email]

 

If it does not prove possible to resolve your complaint informally, I will
arrange for a formal review of the handling of your request according to
the School's procedures. These can be found on SOAS's website at
[3]http://www.soas.ac.uk/infocomp/foi/appea....

 

If you are dissatisfied with SOAS's response following this internal
review, you can apply to the Information Commissioner for a decision on
whether your request has been dealt with in accordance with the
requirements of the Freedom of Information Act or the Environmental
Information Regulations. The Commissioner will normally require you to
have gone through our internal review process first before they consider
your appeal. If the Commissioner finds in your favour, the Commissioner
can require SOAS to release the information to you. The Commissioner can
be contacted at the following address:

 

Information Commissioner

Wycliffe House

Water Lane

Wilmslow

Cheshire SK9 5AF

United Kingdom

 

Further information about your right to appeal to the Information
Commissioner is available on the Commissioner's website
([4]http://www.ico.org.uk/).

 

Yours sincerely

 

David Ogden

Information Compliance Manager

 

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Dear School of Oriental and African Studies,

I am writing to request an internal review of your handling of my FOI request 'Freedom of Information request: advertising for clearing'.

There is a strong public interest in showing how universities spend public money and student fees, as shown by the ongoing debate on university funding. More recently, there has also been increased public interest in university admissions, with a review into this subject by the Office for Students being backed by the education secretary. This information could help that review see how clearing operates and factor into its recommendations on the timing of clearing.

There is also a public interest in ensuring fair commercial competition in a mixed economy, which favours transparency on questions of procurement.

I am therefore very disappointed in your decision.

I also believe the decision reflects neither the exact circumstances of the advertising market nor the ICOs guidance on the subject.

In your response, you argue that releasing information about marketing for clearing would prejudice your commercial interests.

This is incorrect, given the facts of this case, for the following reasons.

1. The University makes money by providing courses to students. It does not seem possible that this information would discourage students attending university -- as ads are known to cost money, the University would not advertise at all if it believed that was the case.

2. The University has a commercial relationship with the advertising platforms (both online and offline) on which it places ads. It would harm the University’s commercial interests if releasing information about marketing caused the price to go up. This is not likely to happen, because:
- As I am asking for the total sums spent on different forms of marketing, I am not asking for price information, which could conceivably be used to drive up the University’s price per ad
- Even if the University did release the price per ad, this should -- according to the ICO’s own guidelines -- causes - prices to fall, by “promoting competition in procurement via transparency”
- In the case of online advertising, prices are set algorithmically, based on the total demand at that time. - Revealing the total spend would therefore not impact the price
- In the case of online advertising, you are competing against every conceivable advertiser at that moment, not just universities. Releasing details of spend is therefore extremely unlikely to raise prices
- Clearing for 2019 has already passed, so this is not relevant to existing negotiations. What’s more, as clearing will not happen again for another year, when the price will have changed, this information is unlikely to be relevant

There is an instance in which prejudice might occur. The University is in competition with other universities for students. It could harm the University if other universities changed their advertising expenditure as a result of the disclosure, thereby outcompeting the University for students.

However, this does not outweigh the public interest in releasing the information, for the following reasons:

1. The ICO’s guidance states that there must be a “causal link” between the disclosure and the prejudice claimed, you must be able to show that this harms you commercially by reducing the number of students on your courses. As students decide on numerous factors, including location, the reputation of the university and the number of places available at the time, the causal link in this case will be weak. There is also no evidence to show that the university “market” operates in this way.

2. The ICO’s guidance specifies that “the severity of the prejudice that may happen also affects the weighting.” As the causal link is extremely unclear, the severity is also likely to be limited.

This being the case, the strong public interest in revealing this information means that the exemption to the FOI Act should not be engaged.

I look forward to your response.

Regards,

Rowland

Information Compliance Manager, School of Oriental and African Studies

Dear Rowland,
I will forward your request for internal review to our Director Legal and
Governance in accordance with our appeal procedures.
We will respond to your request for a review within 20 working days of
receipt (29 October 2019).
Kind regards,
David Ogden
Information Compliance Manager

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Information Compliance Manager, School of Oriental and African Studies

Dear Rowland Manthorpe
Your request for internal review has been completed by our Director of
Legal and Governance.
Decision
The original decision is upheld
Exemptions
The exemption referred in the original decision is applicable.  In
reaching this decision, the ICO Decision notice Ref FS50668371 has been
considered in so far as it relates to Section 43(2) and the public
interest test.  
Kind regards,
David Ogden
Information Compliance Manager

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