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Special category data (TTPA)

Special category data refers to particularly sensitive types of personal information that receive extra protection under EU data protection law. In the context of political advertising, this includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data concerning sex life or sexual orientation. The TTPA regulation strictly limits the use of special category data for targeting or delivering political advertisements.

Legal Basis

"Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation"

— Article 4(15), GDPR (EU) 2016/679, referenced in Regulation 2024/900

The TTPA regulation reinforces these protections by prohibiting the use of special category data for targeting political advertisements except under very specific, limited conditions that comply with both GDPR and the political advertising regulation.

Why It Matters

Special category data protections are critical for preventing discriminatory targeting and manipulation in political advertising. When campaigns use sensitive information like political opinions, religious beliefs, or health data to target voters, they can create filter bubbles, reinforce divisions, or manipulate vulnerable groups. The TTPA's restrictions ensure that political campaigns cannot exploit highly personal information to influence voting behavior.

For political advertisers, publishers, and ad-tech providers, this means implementing strict controls on what data can be used for targeting. Violating these rules can result in significant fines under both GDPR and the TTPA regulation. Platforms and service providers must verify that targeting parameters do not include or infer special category data, even when such data might improve campaign effectiveness.

Citizens benefit from these protections through reduced exposure to manipulative targeting based on their most personal characteristics. The rules help ensure that political debate remains fair and that voting decisions are based on policy positions rather than exploitation of personal vulnerabilities or beliefs.

Key Points

  • Special category data includes racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data, health data, and data about sex life or sexual orientation
  • Using special category data for political ad targeting is generally prohibited under TTPA, with very narrow exceptions requiring explicit consent and legal basis
  • The prohibition applies even to inferred or derived special category data, not just directly collected information
  • Platforms and ad-tech providers must implement technical and organizational measures to prevent special category data from being used in targeting algorithms
  • Violations can trigger penalties under both GDPR (up to €20 million or 4% of global turnover) and TTPA enforcement mechanisms
  • Advertisers cannot circumvent the rules by using proxy data that effectively identifies special categories (such as targeting "readers of religious publications" as a proxy for religious belief)

Special category data vs. Personal data

While all special category data is personal data, not all personal data is special category data. Regular personal data includes information like names, email addresses, location data, or browsing history. Special category data is a subset defined by its sensitivity—information that, if misused, poses heightened risks to fundamental rights and freedoms.

Under GDPR, regular personal data can be processed under six legal bases (including legitimate interest), while special category data requires explicit consent or one of the specific Article 9 exceptions. In political advertising under TTPA, this distinction becomes even more important: basic demographic targeting (age, general location) may be permissible, but targeting based on political opinions or religious beliefs is heavily restricted, regardless of how the data was obtained.

Aspect Personal data Special category data
Examples Name, email, browsing history Political opinions, religious beliefs, health data
GDPR legal bases Six options (Article 6) Explicit consent or Article 9 exceptions required
TTPA targeting Generally permitted with proper legal basis Heavily restricted, narrow exceptions only
Risk level Standard protection Enhanced protection

Related Terms

Special category data (TTPA): Core Facts

Status
Active Definition
Verified
2026-03-07

Related

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.