Nid ydym yn gwybod a yw'r ymateb mwyaf diweddar i'r cais hwn yn cynnwys gwybodaeth neuai peidio - os chi ywRowland Manthorpe mewngofnodwch a gadael i bawb wybod.

Freedom of Information request: advertising for clearing

We're waiting for Rowland Manthorpe to read a recent response and update the status.

Rowland Manthorpe

Dear University of Wales Trinity St David,

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

Paul Osborne, University of Wales Trinity St David

4 Atodiad

Dear Rowland,

 

Thank you for your freedom of information request received by this office
on 9^th September 2019. I will respond to your request as quickly as
possible and within the statutory timeframe.

 

Yours sincerely,

 

Paul Osborne   BSocSc(Hons) LLM,
Solicitor                                                                                                            

Swyddog Diogelu Data   /  Data Protection Officer

Campws Busnes Abertawe SA1 1NE Cymru DU/ Swansea Business Campus, SA1 1NE,
Wales, UK

Llinell Uniongyrchol / Direct Line: 01792
481180                                               

e-bost / e-mail: [1][email address]

 

 

[2]UWTSD Logo

 

 

Trawsnewid Addysg . . . Trawsnewid Bywydau

Transforming Education . . . Transforming Lives

 

[3]Investors in
People[4]cid:image002.jpg@01D1367F.6C534CC0[5]http://www.uwtsd.ac.uk/media/uwtsd-websi...

 Please consider the environment - do you really need to print this email?
/ Cysidrwch yr amgylchedd - a oes wir angen argraffu'r ebost hwn?

 

 

 

 

References

Visible links
1. mailto:[email address]

Paul Osborne, University of Wales Trinity St David

5 Atodiad

 

Dear Rowland,

 

Thank you for your freedom of information request received by this office
on 7^th September 2019. I would respond to your request with the attached
exemption letter.

 

You may request a review of the information contained within this freedom
of information response from my colleague Lee Bartlett 
[1][email address]  If you remain dissatisfied following the
review you may appeal to the Information Commissioner at [2]ico.org.uk.
Alternatively, you may write to the ICO at:

 

Head Office

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a
national rate number

 

Yours sincerely,

 

Paul Osborne   BSocSc(Hons) LLM,
Solicitor                                                                                                            

Swyddog Diogelu Data   /  Data Protection Officer

Campws Busnes Abertawe SA1 1NE Cymru DU/ Swansea Business Campus, SA1 1NE,
Wales, UK

Llinell Uniongyrchol / Direct Line: 01792
481180                                               

e-bost / e-mail: [3][email address]

 

 

[4]UWTSD Logo

 

 

Trawsnewid Addysg . . . Trawsnewid Bywydau

Transforming Education . . . Transforming Lives

 

[5]Investors in
People[6]cid:image002.jpg@01D1367F.6C534CC0[7]http://www.uwtsd.ac.uk/media/uwtsd-websi...

 Please consider the environment - do you really need to print this email?
/ Cysidrwch yr amgylchedd - a oes wir angen argraffu'r ebost hwn?

 

 

 

 

References

Visible links
1. mailto:[email address]
2. https://eur01.safelinks.protection.outlo...
3. mailto:[email address]

Rowland Manthorpe

Dear University of Wales Trinity St David,

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

FoI Requests, University of Wales Trinity St David

Dear Rowland,

Thank you for your email beneath and please accept my apologies for the slight delay in acknowledging this request for an appeal to the University's FOI response as sent 30th September 2019. This matter has now been passed to the University's reviewer who will consider both the original response and your email beneath, and respond to you within the statutory timeframe.

Yours sincerely,

Paul Osborne   BSocSc(Hons) LLM, Solicitor                                                                                                            
Swyddog Diogelu Data   /  Data Protection Officer
Campws Busnes Abertawe SA1 1NE Cymru DU/ Swansea Business Campus, SA1 1NE, Wales, UK
Llinell Uniongyrchol / Direct Line: 01792 481180                                               
e-bost / e-mail: [email address]

dangos adrannau a ddyfynnir

Nid ydym yn gwybod a yw'r ymateb mwyaf diweddar i'r cais hwn yn cynnwys gwybodaeth neuai peidio - os chi ywRowland Manthorpe mewngofnodwch a gadael i bawb wybod.