Freedom of Information request: advertising for clearing

The request was partially successful.

Dear Edge Hill 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

foi, Edge Hill University

Good morning Rowland

Our reference: FOI192014303

Thank you for your recent correspondence requesting information relating to Edge Hill University. Your request was received in our offices on 7th September, 2019 and is being processed in accordance with the Freedom of Information Act 2000. Under the Act, the University is required to provide you with a response within 20 working days. I will write to you in response to your request for information no later than 4th October, 2019.

The Freedom of Information Act includes a number of exemptions to releasing information. Some of these are qualified exemptions, which require us to consider whether it is in the public interest to disclose or withhold the information. In these circumstances, we may need more time to consider your request, and if this is the case, I will write to you by the date above to inform you of when you can expect to receive a response.

If you have any queries regarding this request, please do not hesitate to contact me, quoting the above reference number in all future correspondence.

Kind regards
Nicole Hughes

Assistant Planning Officer
Edge Hill University

show quoted sections

foi, Edge Hill University

Good afternoon Rowland

Our reference: FOI192014302

In relation to the request below, I can confirm it has now been processed in accordance with the Freedom of Information Act 2000. I can confirm that total advertisement spend for clearing in 2019 was £85,105.

On this occasion no data has been provided regarding target audiences and engagement metrics as the University deems this information exempt under Section 43(2) of the Act. '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 University believes disclosure of this information would undermine the commercial interests of the University and other Higher Education Institutions by enabling competitors to benchmark spending and engagement activities.

We trust that this information fully answers your request, however if you are dissatisfied with the handling of your request, you have the right to ask for an internal review, quoting the above reference number in all communications. Internal review requests should be submitted within two months of the date of receipt of the response to your original letter and should be addressed to: Dr C Hutchinson-Howorth, Director of Strategic Planning at the University.

If you are not content with the outcome of your review you may apply directly to the Information Commissioner requesting he review our decision. You must submit your complaint in writing to the Commissioner within six months of receiving the response to review letter. The Information Commissioner can be contacted at: The Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Kind regards

Nicole Hughes
Assistant Planning Officer

show quoted sections

foi, Edge Hill University

Hi Rowland

Please note change in reference number. Correct reference is FOI192014303.

Many thanks
Nicole

show quoted sections

Dear Edge Hill 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

My apologies - I didn't see that you'd given the total figure. Can you please break that down by ad type? Thanks, Rowland

foi, Edge Hill University

Good morning Rowland

Many thanks for your email. I can see you have sent an appeal through and this email following on from that. Please can you confirm your appeal relates to the sums being withheld in question 1?

Kind regards

Nicole Hughes
Assistant Planning Officer
Edge Hill University

show quoted sections