Freedom of Information request: advertising for clearing

The request was refused by University of Derby.

Dear University of Derby,

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

UOD - FOI, University of Derby

4 Attachments

Dear Rowland,

 

Freedom of Information Act 2000 request FOI/1933 

 

I acknowledge your request for information received on 7^th September
2019.                             

 

Your request is being considered and you will receive the information
requested within the statutory timescale of 20 working days as defined by
the Freedom of Information Act 2000, subject to the information not being
exempt or containing a reference to a third party.

 

If you have any queries or concerns then please contact me or
alternatively email the Freedom of Information Team at [1][University of Derby request email].

 

Kind Regards

 

 

+---------------------------------+
|Keira Shetliffe | |
|Information | |
|Governance Assistant | |
|Corporate Information| |
|Governance and | |
|Assurance | |
|  | |
|T: 01332 59 2151 | |
|E: [2][University of Derby request email]| |
|  | |
|University of Derby, | |
|Kedleston Road, | |
|Derby |  |
|DE22 1GB |[4]Tef Gold|
|[3]University of |[5]Gradiuan|
|Derby |top 30 |
+---------------------------------+

 

We are all responsible for protecting personal data held by this
University and who we share that data with. Stop and think before you send
your email. For further guidance visit -
[6]https://www.derby.ac.uk/its/datagov/

 

 

 

Sensitivity: Internal

The University of Derby has a published policy regarding email and
reserves the right to monitor email traffic.
If you believe this was sent to you in error, please reply to the sender
and let them know.

Key University contacts: http://www.derby.ac.uk/its/contacts/

References

Visible links
1. mailto:[University of Derby request email] blocked::mailto:[University of Derby request email]
mailto:[University of Derby request email]
2. mailto:[University of Derby request email]
3. https://www.derby.ac.uk/
4. https://www.derby.ac.uk/about/tef/
5. https://www.derby.ac.uk/
6. https://www.derby.ac.uk/its/datagov/

UOD - FOI, University of Derby

5 Attachments

Dear Rowland,
  
Freedom of Information Act 2000 request FOI/1933

Thank you for your recent request for information.

 

Your request and our responses:

 

Please see attached document.

 

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

 

 

The information that we provide in response to the Freedom of
Information Act 2000 requests are subject to copyright protection. The
copyright is owned by either the University or a third party. Simply
because the information is available under the legislation does not mean
the University or the third party has waived its copyright.

 

If you are dissatisfied with the handling of your request you should
write to:

Mr J Eaglesfield
IT Services
University of Derby
Kedleston Road
Derby
DE22 1GB

 

Please quote your FOI reference no. and ask that your request be
reviewed under the University’s internal appeals procedure.

 

If after the appeal process you are still dissatisfied, you can complain
to the Information Commissioner at: Information Commissioner's
Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Telephone: 01625 545700 [1]www.informationcommissioner.org.uk

 

Kind Regards

 

 

 

+---------------------------------+
|Keira Shetliffe | |
|Information | |
|Governance Assistant | |
|Corporate Information| |
|Governance and | |
|Assurance | |
|  | |
|T: 01332 59 2151 | |
|E: [2][University of Derby request email]| |
|  | |
|University of Derby, | |
|Kedleston Road, | |
|Derby |  |
|DE22 1GB |[4]Tef Gold|
|[3]University of |[5]Gradiuan|
|Derby |top 30 |
+---------------------------------+

 

We are all responsible for protecting personal data held by this
University and who we share that data with. Stop and think before you send
your email. For further guidance visit -
[6]https://www.derby.ac.uk/its/datagov/

 

 

Sensitivity: Internal

The University of Derby has a published policy regarding email and
reserves the right to monitor email traffic.
If you believe this was sent to you in error, please reply to the sender
and let them know.

Key University contacts: http://www.derby.ac.uk/its/contacts/

References

Visible links
1. http://www.informationcommissioner.org.uk/
2. mailto:[University of Derby request email]
3. https://www.derby.ac.uk/
4. https://www.derby.ac.uk/about/tef/
5. https://www.derby.ac.uk/
6. https://www.derby.ac.uk/its/datagov/

Dear University of Derby,

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

UOD - FOI, University of Derby

4 Attachments

Dear Rowland,

 

Freedom of Information Act 2000 request FOI/1933 Internal Review 

 

I acknowledge your request for an internal review of FOI 1933, received on
30^th September 2019.                             

 

Your request is being considered and you will receive the outcome of the
review within the statutory timescale of 20 working days as defined by the
Freedom of Information Act 2000.

 

If you have any queries or concerns then please contact me or
alternatively email the Freedom of Information Team at [1][University of Derby request email].

 

Kind Regards

 

 

+---------------------------------+
|Keira Shetliffe | |
|Information | |
|Governance Assistant | |
|Corporate Information| |
|Governance and | |
|Assurance | |
|  | |
|T: 01332 59 2151 | |
|E: [2][University of Derby request email]| |
|  | |
|University of Derby, | |
|Kedleston Road, | |
|Derby |  |
|DE22 1GB |[4]Tef Gold|
|[3]University of |[5]Gradiuan|
|Derby |top 30 |
+---------------------------------+

 

We are all responsible for protecting personal data held by this
University and who we share that data with. Stop and think before you send
your email. For further guidance visit -
[6]https://www.derby.ac.uk/its/datagov/

 

 

 

Sensitivity: Internal

The University of Derby has a published policy regarding email and
reserves the right to monitor email traffic.
If you believe this was sent to you in error, please reply to the sender
and let them know.

Key University contacts: http://www.derby.ac.uk/its/contacts/

References

Visible links
1. mailto:[University of Derby request email] blocked::mailto:[University of Derby request email]
mailto:[University of Derby request email]
2. mailto:[University of Derby request email]
3. https://www.derby.ac.uk/
4. https://www.derby.ac.uk/about/tef/
5. https://www.derby.ac.uk/
6. https://www.derby.ac.uk/its/datagov/

UOD - FOI, University of Derby

7 Attachments

Dear Rowland
  
Freedom of Information Act 2000 request FOI/1933 Internal Review

Please see attached Document.

 

Kind Regards

 

 

+------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------+
| |Marie Stone | | |
| |Senior Information Governance Assistant | |[5]cid:image002.jpg@01D41929.2E821EA0|
| |Corporate Information Governance & Assurance | | |
| |IT Services | | |
| | |-------------------------------------+-------------------------------------|
| |T: ( (01332) 592001 / ( (07780) 228628 | | |
|[1]images/spacer.gif|E: * [2][email address] * [3][email address] * [4][University of Derby request email]                         | |[6]cid:image004.jpg@01D41929.2E821EA0|
| | | | |
| |University of Derby, | | |
| |Kedleston Road, |-------------------------------------+-------------------------------------|
| |Derby, | | |
| |DE22 1GB | |[7]cid:image006.jpg@01D41929.2E821EA0|
| |-----------------------------------------------------------------------------------------------+-------------------------------------| |
| |[8]cid:image007.jpg@01D41929.2E821EA0 | |[9]cid:image009.jpg@01D41929.2E821EA0| |
|--------------------+------------------------------------------------------------------+----------------------------+-------------------------------------+-------------------------------------|
+------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------+

 

We are all responsible for protecting personal data held by this
University and who we share that data with. Stop and think before you send
your email. For further guidance visit -
[10]https://www.derby.ac.uk/its/datagov/

 

 

Sensitivity: Internal

The University of Derby has a published policy regarding email and
reserves the right to monitor email traffic.
If you believe this was sent to you in error, please reply to the sender
and let them know.

Key University contacts: http://www.derby.ac.uk/its/contacts/

References

Visible links
2. mailto:[email address]
3. mailto:[email address]
4. mailto:[University of Derby request email]
6. https://www.derby.ac.uk/about/tef/
7. https://www.derby.ac.uk/
8. https://www.derby.ac.uk/
10. https://www.derby.ac.uk/its/datagov/