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Freedom of Information request: advertising for clearing

Rowland Manthorpe made this Freedom of Information request to Teesside University as part of a batch sent to 140 authorities

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Dear Teesside 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

Information Legislation, Teesside University

7 Attachments

 

Good morning

 

We acknowledge receipt of your request for information as below. 

 

Your request is being processed in accordance with the Freedom of
Information Act 2000, under our reference number 19186.  That Act requires
that the response to your request is sent within 20 working days following
receipt, subject to any clarification that may be necessary.  Whilst we
will endeavour to provide our response as soon as possible, it will be
issued in accordance with the Act no later than 7 October 2019.

 

If you have any queries in the meantime, please contact us at
[1][Teesside University request email]

 

Yours faithfully

Information Governance Team

 

 

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[3]cid:image001.png@01D2812F.AE636040 Information Governance Team

T: 01642 738188
Legal and Governance Services 
[4]cid:image011.jpg@01D2F419.0CFF3FA0 [5]cid:image008.png@01D27E0D.5D7096A0
[6]cid:image010.png@01D27E0E.301992F0 [7]cid:image011.png@01D27E0E.301992F0 [8]cid:image012.png@01D27E0E.301992F0 [9]cid:image013.png@01D27E31.61AB4FC0 [10]tees.ac.uk  

 

 

show quoted sections

Information Legislation, Teesside University

2 Attachments

Good morning

Please find attached Teesside University's response to your request for information.

Kind regards
Information Governance Team
 

Information Governance Team
T: 01642 738188

Legal and Governance Services

tees.ac.uk
 

Dear Teesside 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

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Dear Teesside 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

Information Legislation, Teesside University

8 Attachments

 

Dear Requestor

 

We acknowledge receipt of your email, in which you ask for a review of our
response to your Freedom of Information request dated 9 September 2019.

 

The University’s appeals process for responses to Freedom of Information
requests (attached) provides for an informal review stage. It is believed
that your queries can be addressed by undertaking an informal review and
we will endeavour to respond to you by 29 October 2019 which is twenty
working days from the date of this email.

 

Should you have any queries, please contact the Information Governance
Team.

 

Kind regards,

Information Governance Team

 

 

[1]cid:image001.png@01D2812F.AE636040 Information Governance Team

T: 01642 738188
Legal and Governance Services 
[2]cid:image011.jpg@01D2F419.0CFF3FA0 [3]cid:image008.png@01D27E0D.5D7096A0
[4]cid:image010.png@01D27E0E.301992F0 [5]cid:image011.png@01D27E0E.301992F0 [6]cid:image012.png@01D27E0E.301992F0 [7]cid:image013.png@01D27E31.61AB4FC0 [8]tees.ac.uk  

 

 

 

Dear Teesside 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

 

 

 

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the internet. Our privacy and copyright policies:

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For more detailed guidance on safely disclosing information, read the
latest advice from the ICO:

[11]https://www.whatdotheyknow.com/help/ico-...

 

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be delayed.

 

If you find this service useful as an FOI officer, please ask your web
manager to link to us from your organisation's FOI page.

 

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Information Legislation, Teesside University

9 Attachments

Good morning

 

Please find attached Teesside University's response to your request for an
internal review of our handling of your FOI request dated 9 September
2019.  

 

A copy of the University's FOI Appeals and Complaints Process is attached
for ease of reference.

 

Kind regards

Information Governance Team

 

 

[1]cid:image001.png@01D2812F.AE636040 Information Governance Team

T: 01642 738188
Legal and Governance Services 
[2]cid:image011.jpg@01D2F419.0CFF3FA0 [3]cid:image008.png@01D27E0D.5D7096A0
[4]cid:image010.png@01D27E0E.301992F0 [5]cid:image011.png@01D27E0E.301992F0 [6]cid:image012.png@01D27E0E.301992F0 [7]cid:image013.png@01D27E31.61AB4FC0 [8]tees.ac.uk  

 

 

show quoted sections

We don't know whether the most recent response to this request contains information or not – if you are Rowland Manthorpe please sign in and let everyone know.