Request for advertising and marketing expenditure
Dear Queen Mary University of London,
I am writing to make an open government request for all the information to which I am entitled under the Freedom of Information Act 2000.
Please could you provide a breakdown of advertising and marketing expenditure by line item. If this could be submitted as an excel that would be much appreciate. Ideally this would cover the following questions:
1. What has been the total annual budget for marketing over the last 5 years (2017-2021)?
2. How much of the marketing budget is spent on in-house marketing and how much is spent on 3rd party providers (e.g. Agencies)?
3. What are they types of third party services used e.g. (managed marketing services, content creators, self-service platforms) and how is the expenditure distributed among them?
4. How much of the marketing budget is spent on digital advertising and how much is spent on traditional advertising methods?
5. What is the segmentation of digital expenditure by channel (e.g. how much is spent on Facebook ads, Google ads etc.) ?
If this request is too wide or unclear, I would be grateful if you could contact me. If any of this information is already in the public domain, please can you direct me to it, with page references and URLs if necessary.
I understand that you are required to respond to my request within the 20 working days after you receive this letter. I would be grateful if you could confirm in writing that you have received this request.
I look forward to hearing from you.
Dear Rohit Somani,
Thank you for your email of 30^th March.
I am pleased to provide the following response.
Although we hold the information you have requested, I am afraid that we
cannot supply it to you. We are unable to supply these figures and
breakdown of spend because we believe this is exempt under s.43(2) of the
Freedom of Information Act. Releasing the spend would be likely to
prejudice our commercial interests if disclosed to the world at large.
This exemption is subject to the public interest test. We recognise that
on the one hand there is always a public interest in the transparency of
an authority and releasing such information may allow for a greater
understanding of what advertising channels are considered useful or
successful. It might also allow comparison across the sector. This would
be in favour of the public interest and releasing.
However, Queen Mary operates in highly competitive markets both nationally
and internationally for staff, research funding and especially for
students. The pandemic has arguably intensified this. Disclosure of
details about our spend and the channels and strategies we use is
commercially sensitive and we believe would be useful to our competitors,
for example by allowing them to adapt their own strategies and approaches.
In financially tough times and while receiving less and less from the
public purse, it is critical that Queen Mary does not imperil its
competitive position in ways that are detrimental to its performance
competing against other HEIs, or its finances. We contend that it would
not be in the public interest if this were to occur and that this
information could give advantages to our competitors once in the public
domain. On balance we therefore believe that the public interest in
maintaining the exemption outweighs the public interest in disclosing the
Furthermore, this information could be considered strategically useful and
its disclosure amount to an infringement of the Competition Act 1998.
Section 44(1)(a) of FOIA exempts the disclosure of information where this
is prohibited by an enactment. This is also an absolute exemption.
We refer you, in addition, to this Decision Notice from the ICO upholding
If you are dissatisfied with this response, you may ask QMUL to conduct a
review of this decision. To do this, please contact the College in
writing (including by fax, letter or email), describe the original
request, explain your grounds for dissatisfaction, and include an address
for correspondence. You have 40 working days from receipt of this
communication to submit a review request. When the review process has
been completed, if you are still dissatisfied, you may ask the Information
Commissioner to intervene. Please see www.ico.org.uk for details.
Records & Information Compliance Manager
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