Freedom of Information request: advertising for clearing

The request was refused by Glyndŵr University.

Dear Glyndŵr 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, Glyndŵr University

Ref: 162_manthorpe_advertising clearing

Dear Mr Manthorpe
I acknowledge your request for information received on 7 September 2019.
Your request is being considered 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 a 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 request 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.
There may be a fee payable for this information. This will be considered and you will be informed if a fee is payable. In this event the fee must be paid before the information is processed and released. The 20 working day time limit for responses is suspended until receipt of the payment.
If you have any queries or concerns then please contact the Freedom of Information Officer, Glyndwr University, Plas Coch, Mold Road, WREXHAM LL11 2AW or e-mail [Glyndwr University request email] or by phone 01978 290666.
Further information is also available from the Information Commissioner at:
Information Commissioner’s Office,
Wycliffe House,
Water Lane,

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Freedom of Information, Glyndŵr University

1 Attachment

Dear Mr Manthorpe
Please find attached the University's response to your Freedom of Information request of the 7 September 2019.
Freedom of Information

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Dear Glyndŵr 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.



Freedom of Information, Glyndŵr University

Dear Mr Manthorpe

I acknowledge your request for an internal review received on 30 September 2019.

A senior member of staff, who has not been involved with the request, will undertake an internal review to ensure that due process has been followed and to determine whether or not sound reasoning in line with the FOIA or EIR has been followed. You may raise a complaint where you believe we have:

• Failed to respond to your request within the time limits (normally 20 working days)
• Failed to tell you whether or not we hold the information
• Failed to provide the information you have requested
• Failed to explain the reasons for refusing a request
• Failed to correctly apply an exemption or exception

You will be informed of the outcome of the internal review within 40 working days, in line with the Information Commissioner’s guidance. The Review will either uphold the original decision, provide additional explanation of the exemption/exception applied or release further information, if it is considered appropriate to do so.

You can also complain to the Information Commissioner at:

Information Commissioner’s Office,
Wycliffe House,
Water Lane,

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Gerry Beer, Glyndŵr University

1 Attachment

Dear Mr Manthorpe
Please find attached the University's response to your request for an Internal Review of the Freedom of Information request relating to advertising for clearing.
Deputy Vice-Chancellor

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