From US Data Dominance to EU Privacy: A New Era for Paid Campaigning

by Shaun Frazao

An American campaign strategist arriving in Brussels for the first time is navigating more than just a new city — they are entering a different political dimension.

They bring with them a formidable toolkit, honed in the vast and dynamic theatre of US politics, where the science of data-driven persuasion has been perfected. Yet, the very precision of these tools can become a liability when applied in a European context, where the rules of engagement are fundamentally different. The challenge is not one of skill, but of adaptation to a new and more complex environment.

The great dividing line in European campaigning is, of course, a comprehensive regulatory philosophy that extends far beyond mere data protection. The foundation — the EU’s General Data Protection Regulation (GDPR) — emphasises personal data as an integral aspect of individual privacy rather than a commercial asset, and forms part of a broader legislative framework that continues to shape Europe’s digital landscape.

More recent additions, the Digital Markets Act (DMA) and the Digital Services Act (DSA), indirectly impact advertising strategies by compelling major tech platforms to disclose more about who pays for ads and the parameters used for targeting. And just this month, the Transparency and Targeting of Political Advertising (TTPA) Regulation has come into effect. This regulation reshapes how the EU defines “political advertising” by tightening the scope as well as introducing significant obligations for transparency and labelling.

In the United States, a different regulatory philosophy has allowed for the development of incredibly sophisticated micro-targeting techniques, where the ability to pick and choose the electorate based on vast datasets of online behaviour is the cornerstone of modern American campaigning. In Europe, however, such methods are not just discouraged; they are, in many instances, illegal or subject to stringent new requirements. A campaign that fails to respect this distinction, and the wider European legislative intent, will not only face legal jeopardy but will also be perceived as culturally out of step.

The easy assumption is that effective, data-informed campaigning is impossible in Europe. A closer look at the rules shows us that it simply demands a different, more nuanced approach.

The reliance on third-party data, so characteristic of many American campaigns, must yield to strategies that flourish in a privacy-first world. While first-party data — such as newsletter subscribers — remains relevant as a “seed” audience for generating “lookalike audiences” and extending reach, its efficacy is frequently constrained by the niche character of policy audiences, which inevitably leads to smaller lists. These limitations, far from representing a technological retreat, ought to be seen as a powerful impetus for greater strategic creativity. Indeed, the new frontier demands elegant, less invasive solutions:

Embrace contextual intelligence, not personal tracking.

In Europe’s privacy-first world, effective messaging depends less on following individuals and more on understanding context. Contextual targeting allows campaigns to place messages where they are most relevant, for example, aligning commentary on financial regulation with the publications and platforms already hosting Europe’s economic policy debates.

Reimagine geo-targeting as a way to influence institutions versus individuals.

The goal is not to target a single official, but to ensure a message is visible across the Brussels policy-making ecosystem, reaching the devices of legislators, staff, and journalists within the institutional heart of the EU. It is a method of influence that respects the line between public discourse and private life while remaining an incredibly precise tool.

Consider compliance not as a burden, but as a strategic advantage, a means to cultivate trust and differentiate oneself from the competition.

In the European cultural landscape, transparency and trust are inextricably linked, valued by both regulators and the public alike. A campaign that diligently nurtures direct relationships with its supporters, meticulously gathering consent-based first-party data and clearly communicating its usage — perhaps through compliant technologies such as data clean rooms — will invariably build credibility and deepen engagement over time. This, surely, is the desired outcome for any enterprise.

In many ways, the challenges of campaigning in Europe today are a preview of the challenges that will define campaigning in America tomorrow. As the US grapples with its own evolving data privacy laws, such as California’s AB 566 — which helps consumers exercise their opt-out rights — the skills being perfected in Brussels will become universally essential. Persuading audiences without harvesting their personal data, and respecting a broader framework of digital rights, is rapidly shifting from a niche European specialism to a global best practice.

Despite this evolving data environment, where privacy is paramount and traditional micro-targeting faces stringent restrictions, the role of paid media has not diminished. Rather, it has become more critical than ever. In a continent of 24 official languages and a constellation of distinct national media landscapes, an organic message can easily be lost or distorted.

A strategic paid media campaign is the only way to guarantee that a specific argument reaches the intended policy audience, in the right language and at the right time. It provides control and clarity in a famously complex environment. Far from being an outdated method, it is the essential tool for speaking with a clear voice in the intricate conversations that shape European policy.