Dear University College London,
I would like to have access to the following information:
- Annual spending on (1) marketing and (2) recruitment (national, EU and international students) since year 2007/2008.
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If you have submitted a Freedom of Information request please accept this
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expect a response from us within 20 working days.
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Data Protection & FOI
Dear Ms Beauchamp,
Apologies for the delay in providing a response to your request for
We have now completed the compilation of information in response to your
We can confirm that we do hold information of the description specified in
Q1) Annual spending on (1) marketing and (2) recruitment (national, EU and
international students) since year 2007/2008.
A1) The requested information regarding marketing and recruitment spend
has been withheld under Section 43(2). Section 43(2) states that:
“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).”
This information has been withheld owing to the prejudice that would occur
to UCL’s commercial interests on account of competitive institutions
becoming aware of UCL’s intentions with regard to student recruitment.
Section 43(2) is a qualified exemption and as such a public interest test
must be performed to establish the harm that would occur from disclosure,
and where the balance of interest lies. Please see below for the outcome
of this public interest test.
Public interest test for the application of Section 43(2):
Arguments in favour of disclosure:
- Release of information concerning how a public authority spends
its money is always considered to be in the public interest.
- The general public should be aware that value for money is being
obtained by the public authority, and that financial operations are being
- There is a general public interest in transparency and openness
with regards to decisions made by public authorities.
Arguments against disclosure:
- UCL competes in a competitive market environment in terms of
recruiting high calibre students to the University’s student population.
UCL compete with other higher education institutions nationally and
globally for this talent.
- To disclose the information requested would affect UCL’s ability
to be competitive in the area of student recruitment by providing other
institutions with otherwise un-disclosed knowledge concerning UCL’s
recruitment strategy. This information would alert institutions UCL
competes against to this strategy, and who could then react on this basis.
For instance, if they were to become aware of UCL’s current and previous
marketing and advertising spend, other higher education institutions could
adopt more aggressive marketing strategies to counter this.
- A negative impact on UCL’s market position would make it harder
for public money to be utilised prudently and would have the effect of
distorting the marketplace UCL operates in. Under UK law UCL is classed as
an ‘undertaking’ and so engaging in the exchange of commercially valuable
information with competitors, which an FOI disclosure would be considered
as, would leave UCL open to investigation and possible punitive action by
If you are unhappy with our response to your request and wish to make a
complaint or request a review of our decision, please email
[email address]. Emails should include the words ‘Internal
Review’ in the subject and be marked For the Attention of the Chief
Operating Officer, alternatively you should write to:
Chief Operating Officer
University College London
Please note, complaints and requests for internal review received more
than two months after the initial decision will not be handled.
If you are not content with the outcome of the internal review, you may
apply directly to the Information Commissioner at the address given below.
You should do this within two months of our final decision.
If you have any queries or concerns, please contact me using the details
provided in this letter and including the request reference number.
Further information on the Freedom of Information Act is available from
the Information Commissioner’s Office:
Data Protection and Freedom of Information Adviser
University College London
Telephone: +44 (0)203 108 7862 (internal 57862)
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