Profiling (political advertising)

Profiling in political advertising means using automated processing of personal data to evaluate, analyse, or predict someone's political opinions, preferences, or behaviour. It is often used to decide which political ads to show someone or to personalise political messages. Under EU law, profiling for political advertising faces strict limits to protect privacy and fairness in elections.

Legal Basis

"Processing of personal data revealing political opinions shall be prohibited."

— Article 9(1), Regulation (EU) 2016/679 (GDPR)

The GDPR defines profiling as:

"any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements."

— Article 4(4), Regulation (EU) 2016/679

Regulation 2024/900 on political advertising restricts the use of profiling and targeting techniques based on personal data, particularly when special categories of data (such as political opinions) are involved.

Why It Matters

Profiling in political advertising affects voters, political actors, and platforms. When providers of political advertising services use profiling, they must comply with strict data protection rules under the GDPR and the political advertising regulation. This means they cannot freely use data about someone's political opinions, ethnicity, religion, or health to target political ads.

For voters, profiling can mean receiving highly personalised political messages designed to influence their vote. While this can help campaigns reach interested voters, it also raises concerns about manipulation, discrimination, and the creation of "filter bubbles" where people only see messages that reinforce existing views. Transparency is essential so voters understand when and why they are being targeted.

Platforms and advertising services must ensure that profiling for political advertising only happens with explicit consent and under lawful conditions. The regulation requires clear information about targeting techniques and prohibits certain uses of personal data, especially special category data, to protect the integrity of elections and the privacy of individuals.

Key Points

Profiling uses automated processing of personal data to predict or analyse political preferences, opinions, or behaviour
Under GDPR Article 9, political opinions are "special category" data with extra protection—processing is normally prohibited
Profiling for political advertising requires explicit consent and must meet strict legal conditions
Regulation 2024/900 restricts targeting and ad-delivery techniques based on personal data, especially for online political ads
Voters have the right to know when profiling is used, what data is processed, and how decisions are made
Platforms must provide transparency about targeting parameters and allow users to opt out or see non-profiled content

Profiling vs. Targeting

Profiling and targeting are closely related but not identical. Profiling is the automated analysis of personal data to predict or evaluate someone's characteristics, preferences, or behaviour. Targeting is the act of directing a political advertisement to a specific person or group, which may or may not use profiling.

You can target an ad without profiling—for example, by showing it to all users in a geographic area. But profiling is often used to enable more precise targeting, such as showing an ad only to users predicted to hold certain political views. Under Regulation 2024/900, targeting and ad-delivery techniques that rely on personal data face strict rules, and profiling for political purposes is particularly restricted because it involves special category data.

Aspect	Profiling	Targeting
Definition	Automated analysis of personal data to predict behaviour or preferences	Directing ads to specific individuals or groups
Requires personal data?	Yes, by definition	Not always (e.g., geographic targeting)
Legal basis	GDPR Article 4(4), Article 9, Article 22	Regulation 2024/900 Chapter III
Main concern	Privacy, manipulation, automated decision-making	Fairness, transparency, misuse of data

Related Terms

Very transparent. Every political ad will be labelled, linked to a transparency notice with detailed information, and online ads will be searchable in a central European repository.

The Network coordinates election-related cooperation between member states. National contact points for TTPA enforcement should be members of this network where possible.

Election campaigns will need to ensure all paid advertising includes proper labels and transparency notices. Sponsors must be prepared to provide required information to all service providers.

Several major platforms currently do not allow paid political advertising, including some large social networks. This limits where political actors can place paid online advertisements.

The TTPA applies from 10 October 2025. Member States had until 10 April 2025 to designate competent authorities, and the Commission must provide label templates by 10 July 2025.

Publishers must ensure completeness and accuracy of certain information but are not required to verify all sponsor claims. They must correct manifestly erroneous information when they become aware of it.

Yes. When a hosting provider and a website both display an ad, both are considered publishers with responsibility for their specific services. Contracts should clarify how they share compliance duties.

If a publisher removes or disables access to a political ad due to illegality or terms violations, they must still provide access to the transparency information for the full seven-year retention period.