Freedom of Information request: advertising for clearing

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

This request has been closed to new correspondence from the public body. Contact us if you think it ought be re-opened.

The request was partially successful.

Dear University of Essex,

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

Freedom Of Information Requests, University of Essex

Dear Rowland

Thank you for your enquiry dated 7th September and received by us on the same date concerning the advertising spend for Clearing 2019 here at the University of Essex. Your request will be handled under the Freedom of Information Act 2000 and will be answered within 20 working days.

In the meantime if you have any questions, please let me know.

Best wishes
Clare Chatfield, BA (Hons), PC.foi
Freedom of Information Team
Innovation & Technology Solutions
University of Essex
Wivenhoe Park
Colchester
Essex
CO4 3SQ
 
T +44 (0)1206 872285
E [University of Essex request email]

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Freedom Of Information Requests, University of Essex

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    University of Essex Freedom of Information Request Clearing advertising spend.xlsx

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Dear Rowland

 

Thank you for your enquiry dated 7^th September and received by us on the
same date concerning the advertising spend for Clearing 2019 here at the
University of Essex.  Your request is being handled under the Freedom of
Information Act 2000.  Please see our response below.

 

Your Request

 

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 – please see attached Excel spreadsheet

2. Instagram – please see attached Excel spreadsheet

3. Google - that is, search advertising – please see attached Excel
spreadsheet

4. YouTube – please see attached Excel spreadsheet

5. Snapchat – please see attached Excel spreadsheet

6. Twitter – we don’t use this channel so this is information not held by
us

7. Other social networks (please specify) – we don’t use this channel so
this is information not held by us

8. Amazon – we don’t use this channel so this is information not held by
us

9. Online - that is, on websites excluding social networks, or those
websites those listed above (this includes advertising using Google's ad
network) – please see the attached Excel spreadsheet

10. Television – we don’t use this channel so this is information not held
by us

11. National newspapers – we don’t use this channel so this is information
not held by us

12. Local newspapers – we don’t use this channel so this is information
not held by us

13. Magazines – we don’t use this channel so this is information not held
by us

14. Posters and billboards – we don’t use this channel so this is
information not held by us

15. Radio – we don’t use this channel so this is information not held by
us

16. Public transport billboards – we don’t use this channel so this is
information not held by us

 

Can you also provide an example of an ad in each of the above formats.
Please see the attached Excel spreadsheet for screenshots of ads which are
no longer live and also for links to some YouTube videos.

 

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. Please see below.

 

For Google advertising, can you list which keywords you advertised
against. Can you please indicate the cost-per-click in each case. Please
see below.

 

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
Please see below.

 

With regards to the above three points, I can confirm that the University
holds the information that you have requested but in this case we will not
be providing it as it is exempt from disclosure.  We are withholding the
information requested above as we consider that the exemption under
Section 43(2), Commercial Interests, of the Freedom of Information Act
applies to it.

 

Section 43(2) of the Act states that

 

(2) ‘information is exempt information if its disclosure under this Act
would, or would be likely to, prejudice the commercial interests of any
person (including the public authority holding it)’. 

 

The Section 43(2) exemptions applies to the three questions above in
entirety.  We believe release of this requested information would harm the
University’s commercial interests.

 

The Information Commissioner’s Office has established a multi-criteria
test for assessing whether a Section 43(2) exemption applies and we
address each criterion in turn.

 

The first criterion is whether the information relates to, or could impact
on, a commercial activity.  We would maintain that the recruitment of
students through Clearing is undoubtedly a commercial activity in the
higher education sector.  The University’s success in recruiting students,
and the manner in which we do so, directly affects both our reputation and
financial position. It therefore follows that information about how the
University markets itself to potential students can be seen as relating to
commercial activity.

 

The second criterion is whether the commercial activity is conducted in a
competitive environment.  The UK Higher Education sector is a highly
competitive environment.  Recent regulatory changes have increased
competition between institutions.  Universities all seek to recruit the
best students from a limited pool of prospective UK and international
applicants, as well as competing to attract high quality staff, research
funding and accreditation.

 

The next criterion is whether the information is commercially sensitive.
The University works with an advertising agency to develop a campaign that
will support its particular plans for recruitment. The demographic
information would reveal the geographic areas and other areas that the
University is targeting. The number of clicks indicates the success, or
otherwise, of the University’s campaign, including which key words, which
demographics and which channels were most effective, and this information
is used to develop next year’s campaign. It is information that could be
used by a direct competitor – i.e. a University wishing to recruit from a
similar demographic or to similar courses – to undermine and directly
challenge the University’s campaign next year. That in turn would mean
that the University’s campaign would be likely to be less effective, and
therefore it would receive less value for money from the campaign.

 

The cost per click is in part related to the success of the campaign, but
is also part of the detail of the University’s contract with the
advertising agency. While the University shares information about
contracts on requests, in line with ICO guidance, it does not share the
detail of contracts, including costs of specific items or activities.
Sharing such information would potentially restrict both the provider’s
ability to set and negotiate its own terms and prices, and the
University’s ability to negotiate best terms from other providers.

 

The final criterion is the likelihood of such prejudice occurring.  The
University believes that disclosure of the requested information would be
likely to prejudice its own commercial interests and its competitiveness
in the Higher Education sector, and in particular its competitiveness in
relation to other universities that target similar demographics or offer
similar courses or experiences.  Significant resources are devoted to the
University’s marketing strategy as the degree to which the recruitment of
the number and value of applicants is now critical to any university’s
success.

 

The Public Interest Test

 

Factors Favouring Disclosure

 

The public have an interest in knowing how public funds are spent.  This
would demonstrate an openness and transparency and would give the public
the opportunity to judge whether the University was using public funds
appropriately and would allow them to debate any issues.

 

In its response the University has shared the marketing costs requested,
demonstrating how public funds are spent in general terms. The details of
the cost per click is not necessary to that openness and transparency.

 

Factors Favouring Non-Disclosure

 

The University of Essex operates in an extremely competitive environment
in relation to student admissions.  Student recruitment is a commercial
activity for all universities and successful recruitment drives income,
investment and reputation.  The University has reason to believe that
other institutions monitor our marketing activities and attempt to match
or exceed them and it seems inconceivable that they would not use
additional information in the same manner.  There is a public interest in
ensuring that the University operates in a proper competitive
environment.  Flattening the market by eliminating points of competitive
difference between institutions is not in the public interest. 

 

Giving due consideration to the points above, whilst we appreciate that
the public have the right to know how public monies are spent, we believe
that the release of this information into the public domain would
undermine the University’s competitive advantage and impact on
recruitment.  Therefore, on balance we feel that prejudice to the
commercial interests of the University outweigh any benefit accruing from
the release of the information and it is therefore in the public interest
to withhold this information under Section 43(2) of the Freedom of
Information Act 2000.

 

I am sorry that we are unable to provide you with all of the information
that you requested.  You have a right to ask us to review this decision
within 40 working days of receipt of this response and you can do that by
contacting our Registrar & Secretary, Bryn Morris, through
[1][email address]. If you are not satisfied with the outcome of a
review then you have a further right of complaint to the Office of the
Information Commissioner at:

 

The Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

Telephone:        08456 30 60 60

Or                     01625 54 57 45

 

Website:           [2]www.ico.org.uk

 

There is no charge for making an appeal.

 

Please accept our apologies for the delay in sending our response to you.

 

Best wishes

Clare Chatfield, BA (Hons), PC.foi

Freedom of Information Team

IT Services

University of Essex

Wivenhoe Park

Colchester

Essex

CO4 3SQ

 

T +44 (0)1206 872285

E [3][University of Essex request email]

 

 

 

 

 

 

 

References

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