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Freedom of Information request: advertising for clearing

Rowland Manthorpe made this Freedom of Information request to University of Greenwich 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.

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Dear University of Greenwich,

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

Lucy Fincham, University of Greenwich

1 Attachment

Dear Mr Manthorpe

In response to your request for information under the Freedom of Information Act 2000:

"A. how much money you spent on advertising for clearing in 2019."

Although we hold this information, we will not be disclosing it as we have applied an exemption, as follows:

Section 43(2) – relating to commercially sensitive information. We believe that a release of such information could potentially weaken our position in a competitive environment by revealing market-sensitive information and therefore undermine our ability to achieve value for money.

This exemption is subject to the Public Interest Test, which we have applied when deciding whether to disclose the information you request. We have decided that it is not in the Public Interest to disclose the information, for the following reasons: to reveal information on the University’s expenditure on marketing could lead competitors to understand how and what benchmarks have been set. Release of strategic, or strategically useful, information would adversely affect the free competition between institutions.

Student recruitment is a commercial activity for all universities. The University’s success in recruiting students, and the manner in which it does so, directly affects both its reputation and financial position. It follows that information about how the University markets itself to potential students can readily be seen as commercially sensitive. The UK Higher Education sector is a highly competitive environment. We do not believe the public interest in information of this type outweighs this.

"B. 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"

Please refer to our answer to question A.

"C. Can you also provide an example of an ad in each of the above formats."

Please see attached document.

"D. For the online forms of advertising, can you also tell me how many clicks each advertisement received."

Although we hold this information, we will not be disclosing it as we have applied an exemption, as follows:

Section 43(2) – relating to commercially sensitive information. We believe that a release of such information could potentially weaken our position in a competitive environment by revealing market-sensitive information and therefore undermine our ability to achieve value for money.

This exemption is subject to the Public Interest Test, which we have applied when deciding whether to disclose the information you request. We have decided that it is not in the Public Interest to disclose the information, for the following reasons: Release of strategic, or strategically useful, information would adversely affect the free competition between institutions.

Student recruitment is a commercial activity for all universities. The University’s success in recruiting students, and the manner in which it does so, directly affects both its reputation and financial position. It follows that information about how the University markets itself to potential students can readily be seen as commercially sensitive. The UK Higher Education sector is a highly competitive environment. We do not believe the public interest in information of this type outweighs this.

"E. Can you also provide any other data you have which indicates the engagement with each ad."

Although we may hold some information in relation to this question, we will not be disclosing it as we have applied an exemption, as follows:

Section 43(2) – relating to commercially sensitive information. We believe that a release of such information could potentially weaken our position in a competitive environment by revealing market-sensitive information and therefore undermine our ability to achieve value for money.

This exemption is subject to the Public Interest Test, which we have applied when deciding whether to disclose the information you request. We have decided that it is not in the Public Interest to disclose the information, for the following reasons: Release of strategic, or strategically useful, information would adversely affect the free competition between institutions.

Student recruitment is a commercial activity for all universities. The University’s success in recruiting students, and the manner in which it does so, directly affects both its reputation and financial position. It follows that information about how the University markets itself to potential students can readily be seen as commercially sensitive. The UK Higher Education sector is a highly competitive environment. We do not believe the public interest in information of this type outweighs this.

"F. For Google advertising, can you list which keywords you advertised against."

Please refer to our answer to question E.

"F.i. Can you please indicate the cost-per-click in each case."

Please refer to our answer to question E.

"G. For Facebook, can you please supply
i. A list of the interests and/or demographics you targeted"

Please refer to our answer to question E.

"ii. If you used custom audiences, where you derived the data to make that custom audience from"

Please refer to our answer to question E.

This letter acts as a partial Refusal Notice.

If you are unhappy with this response, please detail your complaints in writing and send to the University Secretary, Peter Garrod, University of Greenwich, Park Row, London SE10 9LS ([email address] ).

If you are still not happy with our response after this internal review has taken place, you also have a right of appeal to the Information Commissioner at: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF (www.ico.org.uk ).

Yours sincerely

Lucy Fincham
Information Compliance Manager
University of Greenwich
Vice-Chancellor's Office
Old Royal Naval College
Park Row, Greenwich
London SE10 9LS

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