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Freedom of Information request: advertising for clearing

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

We're waiting for Rowland Manthorpe to read recent responses and update the status.

Dear University of Sussex,

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, University of Sussex

1 Attachment

Dear Mr Manthorpe,

 

Thank you for your correspondence received on 7 September 2019.

 

Your request will be dealt with under the Freedom of Information Act 2000
and will be answered as soon as possible and within twenty working days
following the date of receipt, i.e. by 4 October 2019.

 

If you need to contact us about your request please quote your reference
number FOI-19-0218.

 

Kind regards,

 

Information Management Team

Office of the General Counsel, Governance and Compliance

University of Sussex, Sussex House, Brighton BN1 9RH

 

[1]cid:image001.png@01D335FF.FB69BDA0

 

 

References

Visible links

Freedom of Information, University of Sussex

3 Attachments

Dear Mr Manthorpe,

 

Please find attached the University’s formal response to your recent
Freedom of Information request.

 

Yours sincerely,

 

Information Management Team

General Counsel, Governance and Compliance

University of Sussex, Sussex House, Brighton BN1 9RH

 

[1]cid:image001.png@01D53711.47384760

 

References

Visible links

Dear University of Sussex,

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

Freedom of Information, University of Sussex

1 Attachment

Dear Mr Manthorpe,

 

Thank you for your email dated 30 September 2019 concerning our response
to your recent request (FOI-19-0218) under the Freedom of Information Act
2000. 

 

The University is handling your email as a request for an internal review
of our original response of 25 September 2019.  In accordance with
guidance from the Information Commissioner, we will respond within 20
further working days following the date of receipt of your request, i.e.
by 28 October 2019. 

 

Please find below the updated link for the University’s Freedom of
Information internal review procedure:

[1]http://www.sussex.ac.uk/ogs/policies/inf...

 

If you need to contact us about your request please quote your reference
number FOI-19-0218.

 

Yours sincerely,

 

Information Management Team

General Counsel, Governance and Compliance

University of Sussex, Sussex House, Brighton BN1 9RH

 

[2]cid:image001.png@01D335FF.FB69BDA0

 

From: Rowland Manthorpe <[FOI #602209 email]>
Sent: 30 September 2019 17:08
To: Freedom of Information <[University of Sussex request email]>
Subject: Internal review of Freedom of Information request - Freedom of
Information request: advertising for clearing

 

Dear University of Sussex,

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

-------------------------------------------------------------------
Please use this email address for all replies to this request:
[3][FOI #602209 email]

Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
[4]https://www.whatdotheyknow.com/help/offi...

For more detailed guidance on safely disclosing information, read the
latest advice from the ICO:
[5]https://www.whatdotheyknow.com/help/ico-...

Please note that in some cases publication of requests and responses will
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.

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

References

Visible links
1. http://www.sussex.ac.uk/ogs/policies/inf...
3. mailto:[FOI #602209 email]
4. https://www.whatdotheyknow.com/help/offi...
5. https://www.whatdotheyknow.com/help/ico-...

Alex Elliott, University of Sussex

1 Attachment

Dear Mr Manthorpe,

 

I write further to your email of 30 September 2019 requesting an internal
review of the University’s response to your FOI request.

 

Please find attached correspondence detailing the outcome of the internal
review that I have completed.

 

Yours sincerely,

 

Alexandra Elliott

Head of Information Management and Compliance

Division of the General Counsel, Governance and Compliance

University of Sussex

 

From: Rowland Manthorpe <[FOI #602209 email]>
Sent: 30 September 2019 17:08
To: Freedom of Information <[University of Sussex request email]>
Subject: Internal review of Freedom of Information request - Freedom of
Information request: advertising for clearing

 

Dear University of Sussex,

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

-------------------------------------------------------------------
Please use this email address for all replies to this request:
[1][FOI #602209 email]

Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
[2]https://www.whatdotheyknow.com/help/offi...

For more detailed guidance on safely disclosing information, read the
latest advice from the ICO:
[3]https://www.whatdotheyknow.com/help/ico-...

Please note that in some cases publication of requests and responses will
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.

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

References

Visible links
1. mailto:[FOI #602209 email]
2. https://www.whatdotheyknow.com/help/offi...
3. https://www.whatdotheyknow.com/help/ico-...

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.