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Freedom of Information request: advertising for clearing

Rowland Manthorpe made this Freedom of Information request to Goldsmiths, University of London 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 Goldsmiths, University of London,

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

Goldsmiths Information Access, Goldsmiths, University of London

Dear Rowland Manthorpe,

We are writing to formally acknowledge your Freedom of Information (FOI) request received on 7th September 2019. We will respond promptly but in any event by 4th October 2019.

Yours sincerely,

Information Governance
Goldsmiths, University of London
New Cross,
London, SE14 6AF

________________________________________________________________________________________________________________________________________________________________

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Goldsmiths Information Access, Goldsmiths, University of London

Dear Rowland Manthorpe,

I am writing in response to your Freedom of Information request in which you asked:

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

Our response:

I need to inform you that Section 43(2) of the Freedom of Information Act exempts information whose disclosure would, or would be likely to, prejudice the commercial interests of any person (an individual, a company, the public authority itself or any other legal entity).

In this case Section 43(2) of the Act relates to the following:

• the commercial activity is student recruitment in a competitive environment;
• the applicable interests are the commercial interests of Goldsmiths, University of London and its ability to participate competitively;
• the prejudice that the University envisages as a result of disclosure is that it would weaken its position in a competitive environment by revealing information of potential usefulness to its competitors and consequently have a detrimental impact on its level of revenue. The University considers that disclosure of the requested information would provide a competitor with the insight required to undermine its student recruitment strategy.
• the University contends that there is a real and significant risk of such prejudice occurring in that there is significant competitive pressure to sustain and grow tuition fee income across the sector.
This is a qualified exemption under the FOI Act which means that consideration must also be given to whether in all the circumstances of the case the public interest favouring disclosure is greater than the public interest in maintaining the exemption. The public interest means what is in the best interests of the public not what is of interest to the public.

Public interest test considerations:

We have considered whether the public interest in maintaining the exemption outweighs the public interest in disclosing the information. There is a public interest argument that weigh in favour of disclosing the information you have sought:

• The general proposition of maximising openness that the FOIA and the University aspire to;
However, there are also public interest arguments against disclosure:
• Releasing the requested information could prejudice the realisation of the University’s current or future student recruitment strategy.
The University concludes that the disclosure of commercially sensitive information would be likely to have the effect of weakening its position in a vibrant, competitive environment. Therefore, the public interest in withholding the requested information outweighs the public interest in disclosure of the requested information.

Consequently, I need to inform you that your request is refused as Section 43(2) of the Freedom of Information Act exempts information whose disclosure would, or would be likely to, prejudice the commercial interests of any person (an individual, a company, the public authority itself or any other legal entity).

I hope this information satisfies your Freedom of Information request. However, if you are dissatisfied with this response, you may ask for it to be reviewed by either contacting us by email: [email address] or by writing to:

Data Protection Officer
Goldsmiths, University of London
New Cross,
London, SE14 6AF

Please describe the original request, explain your grounds for dissatisfaction, and include an address for correspondence.

If you are still not satisfied following the internal review, you have a right to appeal to the Information Commissioner who can be contacted at the following address.

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 01625 545 700

www.ico.gov.uk

Yours sincerely,
Information Governance
Goldsmiths, University of London

________________________________________________________________________________________________________________________________________________________________________________

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Dear Goldsmiths, University of London,

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

Goldsmiths Information Access, Goldsmiths, University of London

Dear Rowland Manthorpe,

We are writing to formally acknowledge your request for an Internal Review of the response to your Freedom of Information request, FOI Ref: 1797, received on 30th September 2019. Please note that this Internal Review is numbered FOI Ref: 1811 and is the reference to be used in future correspondence relating to your request.

We will respond promptly but in any event by 28th October 2019 this being 20 working days following the receipt of your request and is in accordance with the time limit set out in the FOI Act.

Yours sincerely,

Data Protection Officer
Goldsmiths, University of London
New Cross,
London, SE14 6AF

______________________________________________________________________________________________________________________________________________________________________

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Goldsmiths Information Access, Goldsmiths, University of London

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  • Attachment

    RE FOI Ref 1797 Freedom of Information request Freedom of Information request advertising for clearing.txt

    8K Download View as HTML

Dear Rowland Manthorpe,

 

I am writing to advise you that I have undertaken an Internal Review of
the response to your Freedom of Information. In your original request you
asked:

 

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

 

 

Goldsmiths response to your original request explained that the university
was relying on Section 43(2) of the FOIA and that:

 

§  the commercial activity is student recruitment in a competitive
environment;

§  the applicable interests are the commercial interests of Goldsmiths,
University of London and its ability to participate competitively;

§  the prejudice that the University envisages as a result of disclosure
is that it would weaken its position in a competitive environment by
revealing information of potential usefulness to its competitors and
consequently have a detrimental impact on its level of revenue. The
University considers that disclosure of the requested information would
provide a competitor with the insight required to undermine its student
recruitment strategy.

§  the University contends that there is a real and significant risk of
such prejudice occurring in that there is significant competitive pressure
to sustain and grow tuition fee income across the sector.

 

 

In this instance I am upholding Goldsmiths decision to rely on Section
43(2) of the Freedom of Information Act 2000 (FOIA); the reasons for this
are:

 

§  Higher Education operates in an increasingly marketised environment
where failure to recruit students has a direct impact on the financial
position of the institution. Therefore, clearing performance is critically
important and the success of Goldsmiths advertising campaign during
Clearing has a significant impact on its financial health. Recruitment
through Clearing in 2019 was highly competitive as the year had the third
lowest amount of 18-year-olds since 2000. Furthermore, this will be an
ongoing challenge as, according to data from ONS, it is not expected that
there will be a change in demographic trend until 2022. This has put, and
will continue to put, significant pressure on HE institutions to recruit
students in a highly competitive market where there are more course places
than students. All universities, including Goldsmiths, must compete in
finding ways to maximise their recruitment success through Clearing. For
Goldsmiths using advertising to create brand awareness and to stimulate
initial engagement is particularly important as a means of elevating its
profile in a highly competitive environment.

 

§  Goldsmiths employs a sophisticated and intelligent advertising strategy
to deliver maximum efficacy, engagement and return on ad spend during
Clearing which is unique to Goldsmiths.  Its campaign planning and
strategy begins well in advance of Clearing itself and uses multiple data
points and channels to be able to compete against other institutions that
have more generous marketing budgets.  In Google Ads alone Goldsmiths
keyword strategy involved over 10,000 keywords, almost 1,500 ad variations
and 26,000 other elements to the campaign.  These have all been manually
analysed and selected based on planning, data and insights. Releasing the
information requested into the public domain would provide a competitor
with a detailed understanding of the logic and mechanics of Goldsmiths
approach which would enable them to pre-empt and undermine Goldsmiths
on-going advertising and recruitment strategy. This would significantly
impact on Goldsmiths ability to compete and recruit during Clearing and
this would then impact on its financial position.

 

§  Additionally, as the provider platforms operate on an auction model
disclosing Goldsmiths keyword preferences and how it targets and procures
them would enable its competitors to target the same keywords. This is
likely to result either in Goldsmiths being outbid or procurement costs
being driven up as Goldsmiths would need to place higher bids to reach the
same outcome.

 

 

I note that in your request for an internal review you said:

 

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.

 

In consideration of the public interest test I have concluded that on
balance the public interest in withholding the requested information
outweighs the public interest in disclosure of the requested information.
Although there is a strong public interest in openness, this does not
necessarily override all other arguments. There is also a public interest
in allowing institutions to withhold information which if disclosed would
reduce their ability to negotiate or compete in a commercial environment.
If the commercial secrets of one of the players in the market were
revealed then its competitive position would be eroded and the whole
market would be less competitive with the result that the public benefit
of having an efficient competitive market would be to some extent eroded.
Additionally, I am mindful that Goldsmiths publishes a transparency return
in relation to admissions data and the student body which can be found
here:
[1]https://www.gold.ac.uk/governance/public...
along with annual reports and financial statements which can be found
here: [2]https://www.gold.ac.uk/governance/financ...

 

I hope this satisfies your request for internal review. However, if you
are dissatisfied you have a right to appeal to the Information
Commissioner who can be contacted at the following address.

 

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone: 01625 545 700

www.ico.gov.uk

 

 

 

Jules Spain

Data Protection Officer

Goldsmiths, University of London

+44 (0)20 7919 7947

 

 

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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.