INFORMATION COMPLIANCE TEAM
University Offices, Wellington Square, Oxford OX1 2JD
Ref: FOI/202303/288
25 April 2023
Reply to request for information under the Freedom of Information Act
Your ref
Email of 25th March
_
Would you please be able to disclose the entire PDF of the 'PPE Undergraduate Admissions
Request
manual/procedures' used for the admissions process in 2022/23?
Dear John Smith,
I write in reply to your email requesting the information detailed above.
The admissions manual requested is provided attached here.
Further information can be found here:
Philosophy, Politics and Economics | University of Oxford
We have withheld or redacted any information in the attached document that is exempt from disclosure under
sections 43(2) or 40(2) of the Freedom of Information Act (FOIA).
Application of s43(2) FOIA
We have redacted information relating to contextualised data.
Oxford contextualises GCSE grades based on school performance at Key Stage 4, so that if an applicant has
been relatively high performing, given the attainment of others from similarly performing schools, this would
yield a positive cGCSE score. If an applicant has been underperforming, this would yield a negative cGCSE
score.
We consider any further detail regarding the calculation of GCSE contextualised scores to be exempt from
disclosure under section 43(2) of the Freedom of Information Act (FOIA). Section 43(2) of the FOIA provides
that information is exempt where its disclosure would, or would be likely to, prejudice the commercial interests
of any person. For the reasons given below, we consider that disclosure of the information requested would be
likely to prejudice the University’s commercial interests.
All universities who wish to charge the maximum fee for undergraduate students are required to agree with the
Office for Students (OfS) an Access and Participation Plan (APP), setting out their targets for attracting more
students from historically under-represented groups, including those from disadvantaged backgrounds. If the
OfS is not satisfied that sufficient progress is being made towards a university’s targets, it has the power to
reduce the fee that the university is able to charge its undergraduates. Universities are therefore in competition
with one another to attract and admit students from specific target groups.
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This competition is particularly intense for Oxford and other leading universities (such as the Russel Group),
because they have higher entrance requirements: Oxford generally requires A*A*A to AAA at A-level (or other
equivalent qualifications) depending on the course. This means that Oxford and similar universities are
competing to recruit and admit only the highest-performing students from the specific target groups.
Oxford’s system of contextualising GCSEs is part of our wider consideration of contextual data which should give
Oxford a competitive edge that will enable it to identify more effectively high-performing students from the
target under-represented groups, who would be most likely to thrive on an Oxford degree course. Details of
our use of cGCSEs and other contextual data would be of significant value and interest to Oxford’s main
competitors, who might introduce similar changes to their own admissions processes, offsetting any competitive
advantage that Oxford might gain.
Section 43(2) is a qualified exemption that requires the University to weigh up the public interest in disclosing
the information requested, which is presumed under FOIA, against the public interest in withholding it. The
University recognises that there is a public interest in the disclosure of the information requested. Generally,
there is an interest in openness and transparency in the conduct of the University’s affairs. More specifically,
there is an interest in information relating to the efforts of the University to diversify and broaden its
undergraduate student body. However, we consider that this interest can be met without impairing the
University’s ability to compete with other institutions, and to do so on a level –playing field.
The University already publishes a considerable amount of information on its efforts to widen participation. This
information includes statistics on progress in meeting access targets, as well as details of the University’s
outreach activities across the collegiate University, including projects undertaken by individual departments and
in collaboration with colleges. In our view, this information is more than sufficient to meet the public interest
in disclosure. In addition, it would be contrary to fair competition if one institution were required to disclose
commercially sensitive information separately from other institutions. We therefore consider that the balance
of public interests lies in favour of maintaining the exemption.
S40(2) exemption
We have also redacted any information that might identify individuals where we consider this information to be
exempt from disclosure under section 40(2) of the FOIA. Section 40(2) provides an exemption from disclosure
for information that is the personal data of an individual other than the requester, where disclosure would
breach any of the data protection principles in Article 5 of the GDPR. We consider that disclosure would breach
the first data protection principle, which requires that personal data is processed lawfully, fairly and in a
transparent manner. Disclosure would be unfair to the individuals concerned, because it would be contrary to
their reasonable and legitimate expectations. They would not reasonably expect that information about their
role in the administration of the PPE admissions process would be made public under the FOIA without their
consent. Consequently, there would be no lawful basis to disclose the information under Article 6.1(a) of the
GDPR.
The exemption in section 40(2) is an absolute exemption and is not subject to the public interest test provided
for in section 2(2)(b) of the FOIA. To the extent that the public interest is relevant in this case, the University
considers it is satisfied by the attached information and that the disclosure of names or other identifying
information is not necessary to meet a legitimate public interest.
Please note that the attached information should not be copied, reproduced or used except in accordance with
the law of copyright. In particular, any re-use for commercial purposes would require the permission of the
University and/or any other copyright holders.
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INTERNAL REVIEW
If you are dissatisfied with this reply, you may ask the University to review it by e-mailin
g xxx@xxxxx.xx.xx.xx. A request for internal review should be submitted no later than 40 working days from the date of this letter.
THE INFORMATION COMMISSIONER
If, after the internal review, you are still dissatisfied, you have the right under FOIA to apply to the Information
Commissioner for a decision as to whether your request has been dealt with in accordance with the FOIA. You
can do this online using the
Information Commissioner’s complaints portal.
Yours sincerely
FOI Oxford
Information Compliance Team
