Freedom of Information request: advertising for clearing

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Dear Kingston University,

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

Kingston University, FOI, Kingston University

Dear  Rowland

 

Thank you for your recent request for information relating to Kingston
University. Your request was received on 09/09/2019 and is now being dealt
with under the terms of the Freedom of Information Act 2000.

 

Please note that in some circumstances a fee may be payable prior to
information being supplied.  If a charge is applicable in this case I will
contact you to request payment before proceeding further.  Details of the
University’s charging policy can be found in section 3 of its Freedom of
Information Policy, available at the link below:

 

[1]http://www.kingston.ac.uk/aboutkingstonu...

 

I will be in touch again in due course and in any event not later than
07/10/2019 this being twenty working days following receipt of your
request. In the meantime, please feel free to contact me if I can be of
any further assistance.

 

Kind regards

 

Cathy

…………………………………………….

Cathy Murr

Resources and Compliance Team

Library and Learning Services

Kingston University

 

 

 

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Kingston University, FOI, Kingston University

1 Attachment

Dear Rowland,

Further to your recent request for information, the University’s response
follows.

The University believes that the disclosure of the information you have
requested would be likely to prejudice the commercial interests of the
University and therefore claims the exemption at section 43(2) of the
Freedom of Information Act 2000 from disclosing this information. A Public
Interest Test is attached.

This completes the University’s response to your information request. If
you are unhappy with the service you have received in relation to your
request and wish to make a complaint or request an internal review of our
decision please contact:

Director of VCO and DPO, email : [1][email address] or
by post:  Kingston University, 10 Crescent House, Grove Crescent, Penrhyn
Road Campus, Kingston upon Thames, Surrey KT1 2EE.

In the event that you are not content with the outcome of your complaint
you may then apply directly to the Information Commissioner for a
decision. Generally, the Information Commissioner cannot make a decision
unless you have exhausted the complaints procedure provided by Kingston
University. The Information Commissioner can be contacted at:

The Information Commissioner’s Office, Wycliffe House, Water Lane,
Wilmslow, Cheshire, SK9 5AF.

I hope that you now have the information you require.

Kind regards,

Lyn

-----------------------------------------

Lyn Porteous

Resources and Compliance Team

Library and Learning Services

Kingston University

 

 

From: Kingston University, FOI <[email address]>
Sent: 10 September 2019 16:18
To: Rowland Manthorpe <[FOI #602120 email]>
Cc: Kingston University, FOI <[email address]>
Subject: RE: Freedom of Information request - Freedom of Information
request: advertising for clearing - FOI102074

 

Dear  Rowland

 

Thank you for your recent request for information relating to Kingston
University. Your request was received on 09/09/2019 and is now being dealt
with under the terms of the Freedom of Information Act 2000.

 

Please note that in some circumstances a fee may be payable prior to
information being supplied.  If a charge is applicable in this case I will
contact you to request payment before proceeding further.  Details of the
University’s charging policy can be found in section 3 of its Freedom of
Information Policy, available at the link below:

 

[2]http://www.kingston.ac.uk/aboutkingstonu...

 

I will be in touch again in due course and in any event not later than
07/10/2019 this being twenty working days following receipt of your
request. In the meantime, please feel free to contact me if I can be of
any further assistance.

 

Kind regards

 

Cathy

…………………………………………….

Cathy Murr

Resources and Compliance Team

Library and Learning Services

Kingston University

 

 

 

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Dear Kingston University,

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

Sharma-Drake, Raji, Kingston University

Dear Rowland,
Can I start by apologising, for having missed this request for an internal
review which was recieved by the University, whilst I was on annual leave,
on the 30th September 2019, and sent to me on 1st October
2019.  Unfortunately, I leave the University today, so will not have time
to carry out the internal review prior to my departure. 
I am writing to ask you to  confirm that you still require this internal
review. If so I will pass this onto a colleague who will endeavour to
carry out the internal review and respond as soon as possible.
Kind regards,
Raji Sharma-Drake
Director of USO and VCO

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Sharma-Drake, Mark, Kingston University

Dear Rowland

 

As you will have gathered from Raji’s email below, she has now left the
University, and I have just taken on her responsibilities in this regard,
so apologies for the break in activity.

 

As Raji requested in her email, can you please confirm that you still wish
to progress an internal review, and I will arrange for it to happen.

 

Regards, Mark

 

From: Sharma-Drake, Raji <[email address]>
Sent: 08 November 2019 09:05
To: [FOI #602120 email]
Cc: Kingston University, FOI <[email address]>
Subject: Re: REQUEST FOR INTERNAL REVIEW FOI102074 - FW: Internal review
of Freedom of Information request - Freedom of Information request:
advertising for clearing

 

Dear Rowland,

 

Can I start by apologising, for having missed this request for an internal
review which was recieved by the University, whilst I was on annual leave,
on the 30th September 2019, and sent to me on 1st October
2019.  Unfortunately, I leave the University today, so will not have time
to carry out the internal review prior to my departure. 

 

I am writing to ask you to  confirm that you still require this internal
review. If so I will pass this onto a colleague who will endeavour to
carry out the internal review and respond as soon as possible.

 

Kind regards,

 

Raji Sharma-Drake

Director of USO and VCO

 

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