FOI_25-224 Spend on student recruitment marketing

Date of response: 12 August 2025

We have now considered your request of 22 July 2025 for the following information:

Under the Freedom of Information Act 2000, I request the following information for the last five financial years (e.g. 2020–21 to 2024–25):

Question 1. The university’s total annual expenditure on marketing and advertising aimed at student recruitment.

• A breakdown of that spend across the following categories (if available):

• Social media advertising (e.g. ads on Meta, Instagram, TikTok, LinkedIn, Snapchat)

• Search engine advertising (e.g. Google Ads, Bing)

• Influencer marketing (sponsoring the content of influencers)

• Podcast advertising or sponsorships (third-party or in-house branded)

• Other digital advertising (e.g. display, YouTube pre-roll, programmatic)

• Traditional advertising (e.g. print, radio, out-of-home)

• Events or on-campus promotions for prospective students

Question 2. Whether the university expects student marketing spend to increase, decrease, or remain the same in the 2025–26 financial year.

Our response:

We regret that on this occasion it is not possible to provide the requested information.

In line with section 17 of the Act, this response acts as a Refusal Notice. The Act contains a number of exemptions that allow public authorities to withhold certain information from release. We have applied the following exemption(s) to your request.

To compete in the Higher Education market with leading UK and international universities, the University must ensure that information that would be strategically useful to its competitors is not placed in the public domain. Release of such information would potentially compromise the University’s ability to attract high quality students that allow it to be a progressive and sustainable institution.

The University’s position would be severely compromised if it were to release information which would benefit its competitors.

Marketing encourages prospective students, staff and members of the public to engage with the products and services that the University offers to build relationships, develop the University’s brand and convert prospective customers into paying customers it is undoubtedly a commercial activity for all universities.

The amounts the University invests into marketing and way in which the University directs its marketing funds directly affects both our reputation and financial position. It therefore directly follows that information regarding our marketing spend can readily be seen as commercially sensitive.

The UK Higher Education sector is a highly competitive environment in which universities all seek to recruit the best students from a limited pool of prospective UK and international applicants, attract high quality staff, and success with obtaining research funding and accreditation. With regard to the requested information, the University, in common with other universities, undertakes various advertising activities with the aim of promoting the institution to our target markets, at home and overseas. This is a vital marketing activity that directly affects our ability to compete within the sector.

Expenditure on marketing is regarded as a key indicator of our marketing strategy. The manner in which we direct funding to create a comprehensive and engaging marketing strategy and organise our marketing activities provides us with a possible advantage compared to those competitors who undertake this activity less effectively.

There is a linkage between marketing expenditure and methodology and our ability to attract the desired number and quality of students. Awareness of an institution’s course offering, academic reputation, and local setting is key to any prospective student’s decision to attend. In a very crowded and competitive commercial environment, should the amount and nature of such expenditure be revealed, other institutions will be able to adjust their marketing to match or exceed our activity and thereby impair our ability to recruit quality students.

We believe it is likely that such prejudice to our interests would occur, given the consistent treatment of the information as commercially sensitive, by not only the University but other Higher Education institutions, and the degree to which the recruitment of the number and nature of applicants is now critical to any university’s success.

Our Marketing department would certainly use such information from our competitors. We already have reason to believe that other institutions monitor our marketing activities and attempt to match or exceed them. It seems inconceivable that they would not use additional information in the same manner.

The Information Commissioner’s Office have considered an appeal on similar facts and concluded that it is appropriate to apply s.43(2) to requests for University marketing spend and activity. This is recorded in our link to the decision notice FS506683711.

Public interest test

The application of this exemption requires an examination of the public interest in disclosure as opposed to that in non-disclosure.

Factors in favour of disclosing the information:

• Enhancing the transparency and openness of the marketing / student recruitment advertising process

• Increasing public confidence in the integrity and probity of the marketing / student recruitment advertising process

• There is significant public interest in use of funds by universities to market themselves

Factors in favour of withholding the information are largely laid out in the explanation for the use of the exemption above but would include:

• Protecting the ability of public authorities to compete on a level playing field

• Preventing a distortion of the market for admission to higher education by disadvantaging one institution

• On balance, we therefore believe the public interest lies in withholding the requested information.