To be fair, regardless of their actual reason, public bodies like Universities are compelled by law to treat request that amount to, or could be made as, FOIA r

To be fair, regardless of their actual reason, public bodies like Universities are compelled by law to treat request that amount to, or could be made as, FOIA requests as if they were. I.e. there is no magic incarnation, set of words or similar that need to be uttered to make it so. It's similar to requests under the DPA. As always there are grey areas, and I'm not making a judgement as to whether, even if it was considered an FOIA request, it would be considered Vexatious (I don't know enough detail). But it is incumbent upon them to consider it as such.