Dear W Tanner

I acknowledge receipt of your email received by this office on 6 March 2020 in which you requested information regarding spend on undergraduate courses.

Your request will now be dealt with under the Freedom of Information Act 2000 and has been allocated reference FOI20-105 which should be quoted in all correspondence. We will respond to your request within 20 working days starting the next working day after receipt, therefore you can expect to receive a response no later than 6 April 2020.

Where we consider that we will not be able to meet this deadline or if further time is required to consider the public interest test we will contact you as soon as possible and give you a revised date for response.

In some circumstances a fee may be payable and, if that is the case, we will let you know. A fees notice will be issued to you, and you will be required to pay before we will proceed to deal with your request.

Yours sincerely

Gwasanaeth Sicrwdd
Adran Cynllunio Strategol a Llywodraethu
Prifysgol Caerdydd
2il Lawr, Friary House
Heol y Brodyr Llwydion
Caerdydd
CF10 3AE
Ebost : [email address]  

Mae'r Brifysgol yn croesawu gohebiaeth yn Gymraeg neu'n Saesneg.  Ni fydd gohebu yn Gymraeg yn creu unrhwy oedi.
Assurance Services
Strategic Planning and Governance
Cardiff University
2nd Floor, Friary House
Greyfriars Road
Cardiff
CF10 3AE
Email: [email address] 

The University welcomes correspondence in Welsh or English.  Corresponding in Welsh will not lead to any delay.

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Dear W Tanner

I am writing in response to your Freedom of Information request dated 6
March 2020.

For ease of reference, I have reproduced your questions below and set out
our corresponding responses.

In each of the financial years from 1998-99 to 2018-19 how much has your
institution spent on advertising and marketing of undergraduate degrees?
This should exclude open days and publication costs if possible.

If possible please break down this spending by different types of
advertising and marketing:

-              Print

-              Traditional media

-              Social media

-              Search engine

-              Direct advertising

In addition to our central marketing team, marketing activities are also
carried out by individual schools and departments within the University
and the information you have requested is not routinely collated
centrally. As there are 24 Academic Schools and numerous departments it
would take considerably more than 18 hours to collate the information you
require. The University is not obliged to spend more than 18 hours (as set
by the Freedom of Information and Data Protection (Appropriate Limit and
Fees) Regulations 2004) collating such information and accordingly the
exemption provided by section 12(2) of the Freedom of Information Act 2000
will apply.

After due consideration it is also considered that this information would
in any event be exempt from disclosure by virtue of Section 43 of the
Freedom of Information Act entitled Commercial Interests. This section
states:

43(2) 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 information requested contains data that would give insight into the
University’s activities that would be likely to prejudice its commercial
interests. The University operates in a highly competitive market in
attracting students. To disclose this information into the public domain
would put the University at a commercial disadvantage by exposing their
recruitment strategy and key business information to competitors, who
could exploit that information for their own competitive gain.
Furthermore, sharing of commercially confidential information between
competitors is normally prohibited under the Competition Act 1998 as this
could have an adverse impact upon competition in that market.

In order to apply, the exemption requires that a public interest be
considered and this is documented below:

Public Interest Test

Factors in favour of disclosure

Openness and Transparency - It is in the public interest that
University's, as public authorities, are as open and transparent as
possible in the way that they operate and the way in which decisions are
made.

Factors in favour of non-disclosure

Commercial Interests - It is not in the public interest to disclose
information that would undermine the ability of the University to
differentiate itself from competitors and maintain its position within the
market.

Efficiency and effectiveness – It is not in the public interest to
disclose information that would erode the efficiency and effectiveness of
the organisation by eroding its opportunity’s to develop income and
undermine its ability to use that income for reinvestment in its public
task.

Given the above, it is considered that it is in the greater public
interest to withhold the information from disclosure at this time.

I trust this information satisfies your enquiry.  The University has a
Freedom of Information Complaints Procedure should you feel dissatisfied
with this response or the way in which your request was handled.
Complaints must be made in writing and must set out why you believe the
University has not met its obligations under the Freedom of Information
Act.  You may email your complaint to [email address] where it
will be forwarded to the Director of Strategic Planning and Governance who
will be responsible for overseeing the review.

If you remain dissatisfied following the outcome of your complaint, you
have the right to apply directly to the Information Commissioner for
consideration.  The Information Commissioner can be contacted at the
following address: Information Commissioner's Office, Wycliffe House,
Water Lane, Wilmslow, Cheshire, SK9 5AF.

I would like to take this opportunity to thank you for your interest in
Cardiff University. If you require further assistance please feel free to
contact me.

Yours sincerely

Assurance Services   Gwasanaeth Sicrwdd
Strategic Planning & Governance   Adran Gynllunio Strategol a
Llywodraethu
Cardiff University   Prifysgol Caerdydd
2nd Floor, Friary House   Llawr 2, Friary House
Greyfriars Road   Heol y Brodyr Llwydion

Cardiff Caerdydd
CF10 3AE   CF10 3AE
E-mail: [1][email address]   E-bost:
[2][email address]
We welcome correspondence in Welsh
or English Rydym yn croesawu gohebiaeth trwy’r
Gymraeg neu’r Saesneg

References

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