Freedom of Information request: advertising for clearing

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

Waiting for an internal review by Bangor University of their handling of this request.

Dear Bangor 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 Compliance Shared mailbox, Bangor University

Our Ref. FOI1880

 

Dear Rowland Manthorpe,

 

Thank you for your Freedom of Information request, received by email on
the 7^th September 2019.

 

We will now consider your request 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 reference to a third party.

 

For your information, the Act defines a number of exemptions which may
prevent release of the information you have requested. There will be an
assessment, and if any of the exemption categories apply then the
information will not be released. You will be informed if this is the
case, including your rights of appeal.

 

If the information you requested contains reference to a third party, then
they may be consulted prior to a decision being taken on whether or not to
release the information to you. You will be informed if this is the case.

 

If you have any queries please contact us.

 

Kind regards,

Compliance Team

 

[1]http://www.bangor.ac.uk/emailtpl/logo-a2... Tîm Cydymffurfio Compliance Team

Llywodraethu a Chydymffurfio Governance and Compliance

Gwasanaethau Corfforaethol Corporate Services

E-bost: [2][Bangor University request email] Email: [8][Bangor University request email]

Prifysgol Bangor, Bangor, Gwynedd, LL57 2DG Bangor University, Bangor, Gwynedd, LL57 2DG

Elusen Gofrestredig: Rhif 1141565 Registered Charity: No. 1141565

[3]http://www.bangor.ac.uk/emailtpl/twitter... [9]http://www.bangor.ac.uk/emailtpl/twitter...
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[7]FfRhA Aur [13]TEF Gold

 

 

 

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Information Compliance Shared mailbox, Bangor University

Our Ref. FOI1880

 

Dear Rowland Manthorpe,

 

Further to your request for information, the University’s response is
below:

 

The University believes that information relating to marketing spend is
exempt information under Section 43(2)(Commercial Interest), Freedom of
Information Act 2000. Section 43(2) provides that 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).

 

Please note that the University has a formal complaints procedure. If you
are unhappy with the service you have received in relation to your request
and wish to make a complaint or request a review of our decision you
should write to the University’s Governance & Compliance Office in the
first instance ([1][Bangor University request email]) explaining the grounds
for your complaint. In line with guidance from the Information
Commissioner’s Office, an appeal request must be submitted within two
months of the University’s final response to this Freedom of Information
Act request.

 

Kind regards,

Compliance Team

 

[2]http://www.bangor.ac.uk/emailtpl/logo-a2... Tîm Cydymffurfio Compliance Team

Llywodraethu a Chydymffurfio Governance and Compliance

Gwasanaethau Corfforaethol Corporate Services

E-bost: [3][Bangor University request email] Email: [9][Bangor University request email]

Prifysgol Bangor, Bangor, Gwynedd, LL57 2DG Bangor University, Bangor, Gwynedd, LL57 2DG

Elusen Gofrestredig: Rhif 1141565 Registered Charity: No. 1141565

[4]http://www.bangor.ac.uk/emailtpl/twitter... [10]http://www.bangor.ac.uk/emailtpl/twitter...
[6]http://www.bangor.ac.uk/emailtpl/faceboo... [12]http://www.bangor.ac.uk/emailtpl/faceboo...

[8]FfRhA Aur [14]TEF Gold

 

 

 

 

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Dear Bangor 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