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Freedom of Information request: advertising for clearing

Rowland Manthorpe made this Freedom of Information request to Falmouth 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 Falmouth 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 Office, Falmouth University

6 Attachments

 

Dear Mr Manthorpe

 

Freedom of Information Request FOI0465 – Advertising for Clearing

 

Thank you for your email of 7 September 2019 requesting information about
advertising for clearing.

 

Your request is being dealt with under the terms of the Freedom of
Information Act 2000 and will be answered within twenty working days.

 

In the meanwhile your request has been sent to the relevant department/s
seeking answers to all the questions that you have posed.

 

If you have any queries about this request do not hesitate to contact me.
Please remember to quote the reference number above in any future
communications.

 

Yours sincerely

 

 

Information Governance Officer

Falmouth University, Falmouth Campus, Woodlane, Falmouth, Cornwall TR11
4RH

 

[1]www.falmouth.ac.uk/information-records-management

 

 

 

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Information Office, Falmouth University

6 Attachments

 

Dear Mr Manthorpe

 

Freedom of Information Request FOI0465 – Advertising for Clearing

Thank you for your email of 7 September 2019 requesting information about
advertising for clearing.

We have dealt with your request under the Freedom of Information Act
2000.  I can confirm that we hold this information.

 

The information requested is exempt under section 43(2) of the Freedom of
Information Act 2000, which relates to Commercial Interests.  The test for
exemption is whether or not the individual’s, in this case the
University’s, commercial interests would be prejudiced by disclosure. 
According to [1]ICO guidance, “[a] commercial interest relates to a
person’s ability to participate competitively in a commercial activity.
The underlying aim may be to make a profit however it could also be to
cover costs or to simply remain solvent.”

 

In particular, we have based the justification on the points below:

·       Universities are operating in an extremely competitive commercial
market.

·       Marketing activity during the Clearing period is increasingly
aggressive, when universities are in direct competition with one another
and digital marketing is a key campaign tool.

·       Release of the total sum, and particularly the breakdown of
spending across channels, would not only provide competitors with insight
into the University’s recruitment ambitions and campaign tactics, it could
potentially allow them to out-spend the University next year.

·       Providing clicks and engagement would provide competitors with a
detailed understanding of the objectives and efficacy of our marketing
campaigns.

·       Providing the keywords for Google search and the cost-per-click,
as well as details of our Facebook targeting, would effectively be
revealing our paid-advertising strategy to competitors.

 

The University considers that such a disclosure would prejudice the
commercial interests of the University. A disclosure under the legislation
is a disclosure to the world at large. If the information were disclosed,
it would give other companies with similar services, i.e. Higher Education
establishments, a competitive advantage that would put our recruitment
processes at a disadvantage. If disclosed, the information requested would
erode the competitive position of the University and could result in the
whole commercial environment being less competitive.

 

Section 43(2) is a prejudice-based exemption and therefore also subject to
a public interest test. It is recognised that there is a general public
interest in the disclosure of commercial information to ensure, for
example, transparency in the accountability of public funds. However,
where disclosure would make it less likely that companies or individuals
would provide the department with information in the future, or where
disclosure would make it more difficult for the University to compete
commercially, these are factors that may weigh in favour of
non-disclosure.

 

While the University is aware that disclosure of such information as that
requested would further the public understanding of how public money is
spent, the University finds, at this time, that the public interest in
withholding the information outweighs the public interest in disclosure.
It is on this basis that your request is refused.   

 

Appeal Process

 

If you are dissatisfied with the handling of your request, you have the
right to ask for an internal review. Internal review requests should be
submitted within two months of the date of receipt of the response to your
original communication and should be addressed
to: [2][email address] or sent in writing to Peter Cox, Chief Operating
Officer, Falmouth University, Penryn Campus, Treliever Road, Penryn, TR10
9FE. 

 

If you are not content with the outcome of the internal review, you have
the right to apply directly to the Information Commissioner for a
decision. The Information Commissioner can be contacted at:

Information Commissioner's Office,

Wycliffe House, Water Lane,

Wilmslow, Cheshire

SK9 5AF.

 

If you have any queries about this email, please contact me.

 

Yours sincerely,

 

Information Governance Officer
Falmouth University, Falmouth Campus, Woodlane, Falmouth, Cornwall TR11
4RH

 

[3]www.falmouth.ac.uk/information-records-management

 

 

 

 

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Dear Falmouth 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

Information Office, Falmouth University

6 Attachments

 

Dear Mr Manthorpe

 

FOI request FO10465

 

Thank you for contacting us about the above FOI request. 

 

An internal review will now be conducted and the University aims to
respond to you within 20 working days.

 

If you have any questions in the meantime, please contact us and quote the
reference number above. 

 

Kind regards,

 

Information Officer 

 

Falmouth University, Falmouth Campus, Woodlane, Falmouth, Cornwall TR11
4RH 
[1]www.falmouth.ac.uk/information-records-management 

 

 

 

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Bull, Ben, Falmouth University

10 Attachments

 

Dear Mr Manthorpe,

 

We write further to your e-mail dated 11^th October 2019 in which you
asked for an internal review of your Freedom of Information Act 2000
(“FOIA”) request for:

 

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.

(the “Request”)

 

In considering whether to disclose the requested information the
responsible Information Officer looked to apply an exemption under Section
43(2) (the “Exemption”) on the grounds that the disclosure would, or would
be likely to, prejudice the University’s commercial interests.

 

In your request for review you refer to facts which we perceive to be
assumptions, therefore it is important that we provide clarity to
accurately consider the Request.

 

1. The University makes money by providing courses to students

 

The University derives some of its income from student fees which in real
terms makes up 84% of its total income (see
finance_report_2017-2018_updated_ (1).pdf and finance_figures_2019.pdf).

 

2. The University has a commercial relationship with the advertising
platforms (both online and offline) on which it places ads.

 

The University engages a third-party commercial entity to undertake online
advertising campaigns on its behalf and does not engage directly with the
platforms mentioned in the Request directly. 

 

In reviewing the application of the Exemption to the Request we have
considered several elements to balance the probability of prejudice versus
the public interest in the specific information you seek.

 

Guidance produced by the Information Commissioner’s Office (the “ICO”)
makes clear that information about the procurement of goods and services
by a public authority is usually considered to be commercially sensitive,
including details of a contract or transaction with a third party.

 

In applying the Exemption, the University must satisfy itself that
disclosure of the information would, or would be likely to, prejudice or
harm the commercial interests of any person which in this instance
includes both the University, and the contracted third party.  Guidance
produced by the ICO makes clear that the term “would…prejudice” means that
prejudice is more probable that not to occur.  The term “would be likely
to prejudice” is a lower threshold than “would…prejudice” and the ICO
states that this mean that the probability of prejudice occurring is less
than 50%.

 

There is a strong public interest in University expenditure; we make every
effort to provide transparency through the publication of audited
financial statements and in the last year a joint publication between the
University and its students’ union which shows how revenue is generated
and how that money is spent (see financial_figures_2019.pdf). 

 

In reviewing the criteria used by the responsible Information Officer we
agree with their initial decision to apply a Section 43(2) exemption to
the Request. 

 

The University is currently reviewing its marketing functions and
expenditure, and specifically is engaging in a retendering process for the
procurement of online campaigns including advertising.  We strongly
believe that the disclosure of the total amount spent on the current
contract as detailed in the Request would be likely to prejudice ongoing
negotiations both for the University and the current third-party
commercial entity who were engaged in the last round of clearing
activities.  Any action which would be likely to prejudice this process
would not be in the public interest as the University could be forced to
pay more for goods and services related to advertising, leaving less money
available for the provision of higher education.

 

In the case of John Connor Press Associates v The Information Commissioner
EA/2005/0005 the Tribunal accepted that the commercial interests of a
public authority might be prejudice if certain information in relation to
one transaction were to become available to a counterparty in negotiations
on a subsequent transaction.  If those commercial entities engaging in our
tender process are able see how much was paid previously for clearing
campaigns, they may not be motivated to provide the best possible value
for their services.

 

In the Request you asked for copies of ads we have used across different
platforms which we are happy to provide.  These were missed in the
original response, therefore please find attached the archive
“examples.zip” which contains examples of campaigns run by our commercial
third party on Facebook, Instagram and Google.  These examples also show
the number of impressions where known along with the “clicks” and “CTR” as
a percentage.

 

We would also like to provide the following additional information which
you may find of interest.

 

The University is committed to financial transparency and publishes every
year a set of audited financial statements which can be found here;

 

[1]https://www.falmouth.ac.uk/corporate/reg...

 

Further to these statements, the University also published a joint set of
Finance Figures for 2019 along with the student’s union so that all key
stakeholders would have access to information to understand how Falmouth
University generates revenue and how that money is spent.  This document
can be downloaded here;

 

[2]https://www.falmouth.ac.uk/file/37777/do...

 

The University publishes updates to these documents on a yearly basis.

 

Any procurement by the University is subject to the Procurement Policy
(see Falmouth Procurement Policy 2018.pdf) and the expenditure of the
University is detailed within its audited financial statements and most
recently its “Finance Figures” document (see finance_figures_2019.pdf)
which provides transparency around marketing expenditure.

 

The University spends 5.41% of its undergraduate fees and 5.5% of its
postgraduate fees on Marketing.

 

Yours sincerely,

 

 

Ben Bull

Information Governance Manager & DPO

Digital Experience and Information Services

 

Office: 01326 255775

Falmouth University
Falmouth Campus, Woodlane, Falmouth, Cornwall, TR11 4RH

 

[3][email address

[4]www.falmouth.ac.uk

 

 

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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.