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Freedom of Information request: advertising for clearing

Rowland Manthorpe made this Freedom of Information request to Coventry 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.

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

Dear Coventry 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

Freedom of Information requests, Coventry University

Dear Mr Manthorpe,

REF: Freedom of Information Request – FOIA1021

Please accept this email as an acknowledgement that the University has received your request of below.

The University will respond under the Act by no later than the 23rd September 2019.

Kind Regards

Will Doherty | Registry Officer – Information Governance | Information Governance Unit (IGU)
Coventry University, Alan Berry Building, Priory Street, Coventry, CV1 5FB
T: +44 (0)2477 658202 | M: +44 (0)7557425844 | E: [email address] |
W: www.coventry.ac.uk
Working hours: Monday – Friday 08.30am – 17.00pm

The contents of this email (including any attachments) are confidential, may be legally privileged, and are for use only by the intended recipient(s). If you are not an intended recipient, you must not use or disclose the contents to anyone; instead, please notify the sender immediately by reply email or by calling +44 (0)24 77 65 7777 and then delete this email.

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William Doherty, Coventry University

Dear Mr Manthorpe,

REF: Freedom of Information Request - FOIA1021

The University has completed its search for the information requested by you under the Freedom of Information Act. Your request related to how much money Coventry University spent on advertising for clearing in 2019.

In response to your request, I can confirm that Coventry University holds the information you are seeking. However, the exemption available under Section 43 of the FOIA exempts the requested information because the information is deemed commercially sensitive. The release of such information would be likely to prejudice the commercial interests of the University. This exemption is subject to the public interest test.

The public interest test has been applied as follows:

Factors in favour of disclosure:

*Transparency and accountability.

Factors in favour of withholding disclosure:

*It is necessary that the University maintains its competitive position on the open market and it would be likely that the release of the information may potentially harm any competitive advantage it may have. Sharing our marketing spend could be used to gain competitive advantage or to allow advertisers to gain insight on budgets, which could influence their pricing.

Having considered the public interest test, Coventry University is satisfied that the public interest in withholding the information outweighs the public interest in disclosing it.

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 Information Governance Unit, Coventry University, Alan Berry Building, Priory Street, Coventry, CV1 5FB or email [Coventry University request email].

If you believe that the University has not dealt with your request in accordance with the FOIA, please be advised that you have the right to have this decision reviewed via the University's complaints procedure, a copy of which can be provided upon request.

If you are not content with the outcome of your complaint, you may apply directly to the Information Commissioner for a decision. Generally, the ICO cannot make a decision unless you have exhausted the complaints procedure provided by the University. The Information Commissioner can be contacted at: The Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF; Tel: 01625 545 745; Email: [email address]

Kind Regards

Will Doherty | Registry Officer - Information Governance | Information Governance Unit (IGU)
Coventry University, Alan Berry Building, Priory Street, Coventry, CV1 5FB
T: +44 (0)2477 658202 | M: +44 (0)7557425844 | E: [email address] |
W: www.coventry.ac.uk
Working hours: Monday - Friday 08.30am - 17.00pm

Please visit IGU's SharePoint site for more information by clicking on the link below:

https://share.coventry.ac.uk/staff/ps/IP...

The contents of this email (including any attachments) are confidential, may be legally privileged, and are for use only by the intended recipient(s). If you are not an intended recipient, you must not use or disclose the contents to anyone; instead, please notify the sender immediately by reply email or by calling +44 (0)24 77 65 7777 and then delete this email.

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Dear Coventry 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

Freedom of Information requests, Coventry University

Dear Mr Manthorpe,

REF: Freedom of Information Request - FOIA1021

Please accept this email as an acknowledgement that the University has received your request for an internal review of your Freedom of Information Request response.

The University will respond to you no later than the 28th October with its response.

Kind Regards

Will Doherty | Registry Officer – Information Governance | Information Governance Unit (IGU)
Coventry University, Alan Berry Building, Priory Street, Coventry, CV1 5FB
T: +44 (0)2477 658202 | M: +44 (0)7557425844 | E: [email address] |
W: www.coventry.ac.uk
Working hours: Monday – Friday 08.30am – 17.00pm

Please visit IGU’s SharePoint site for more information by clicking on the link below:

https://share.coventry.ac.uk/staff/ps/IP...

The contents of this email (including any attachments) are confidential, may be legally privileged, and are for use only by the intended recipient(s). If you are not an intended recipient, you must not use or disclose the contents to anyone; instead, please notify the sender immediately by reply email or by calling +44 (0)24 77 65 7777 and then delete this email.

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Freedom of Information requests, Coventry University

Dear Mr Manthorpe,

REF: FOIA1021 - Internal Review

Thank you for your email of 30 September 2019, in which you requested a review of the University's decision not to disclose information relating to advertising for Clearing on the basis of commercial sensitivity.

The review of this decision has now been completed and I must advise that the outcome is to uphold the original decision. The reasons for upholding the original decision are as follows:

* It is necessary that the University maintains its competitive position on the open market and it would be likely that the release of the information may potentially harm any competitive advantage it may have.
* Sharing our marketing spend could be used to gain competitive advantage or to allow advertisers to gain insight on budgets, which could influence their pricing.

On the basis of the above it has been determined that the potential prejudice to commercial interests outweighs the public interest in disclosure of this information and therefore the original decision has been upheld.

If you are not content with the outcome of your review, you may apply directly to the Information Commissioner for an external review of the University's decision. The Information Commissioner can be contacted at: The Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF; Tel: 01625 545 745; Email: [email address]

Kind Regards

Information Governance Unit (IGU)
Coventry University, Alan Berry Building, Priory Street, Coventry, CV1 5FB
T: +44 (0)2477 658202 | M: +44 (0)7557425844 | E: [email address] |
W: www.coventry.ac.uk

Please visit IGU's SharePoint site for more information by clicking on the link below:

https://share.coventry.ac.uk/staff/ps/IP...

The contents of this email (including any attachments) are confidential, may be legally privileged, and are for use only by the intended recipient(s). If you are not an intended recipient, you must not use or disclose the contents to anyone; instead, please notify the sender immediately by reply email or by calling +44 (0)24 77 65 7777 and then delete this email.

show quoted sections

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.