Three roles, one step
Steps 3 and 4 of the wizard ask you to identify up to three parties involved in your advertisement: the sponsor, the payer, and the data controller. In many cases, these are all the same person or organisation. But when they differ, the regulation requires you to disclose each one separately.
This article explains the legal meaning of each role, when you need to provide separate details, and what fields are required.
The sponsor
The sponsor is the person or organisation that initiated, ordered, or arranged for the advertisement to be placed. Under Art. 9(1)(a) PAR, every transparency notice must identify the sponsor.
In practice, the sponsor is whoever decided that this ad should exist and took the steps to make it happen. That might be a political party commissioning a billboard, a candidate ordering campaign flyers, or an advocacy group placing an online ad.
Required fields
- Legal name -- The official registered name of the person or organisation. For an individual, use your full legal name. For an organisation, use the name as it appears in official registers.
- Postal address -- A physical mailing address. This must be an address where correspondence can be received.
Recommended fields
- Email address -- Not strictly required by Art. 9(1)(a), but strongly recommended. Including an email makes it easier for citizens and regulators to reach you.
Saving time with sponsor templates
If you create notices regularly with the same sponsor details, you can save those details as a sponsor template. The next time you create a notice, select the template from the dropdown at the top of the sponsor step and all fields are pre-filled instantly. Sponsor templates are available on Pro plans and are shared across your organisation.
If your organisation uses chapters (for example, regional branches), chapters can set their own default sponsor details. When a notice is created within a chapter, the chapter's sponsor defaults are applied automatically.
The payer
The payer is the person or organisation that provided the funds for the advertisement. Under Art. 9(1)(a) PAR, if the payer is different from the sponsor, the payer must be disclosed separately.
When is the payer different from the sponsor?
The most common scenarios are:
- A party branch pays for a candidate's ad. The candidate is the sponsor (they initiated the ad), but the regional party branch is the payer (they provided the money).
- A coalition or umbrella organisation funds ads on behalf of members. Each member organisation may sponsor their own ads, but the central body pays.
- A third party funds an ad on someone's behalf. For example, a supporter pays for an ad that a candidate ordered.
If you are paying for your own ad out of your own budget, the payer and sponsor are the same. In that case, leave the "Payer is different from sponsor" checkbox unchecked and no additional fields appear.
Required fields (when payer differs)
- Name -- Full legal name of the payer.
- Email -- Contact email for the payer.
- Postal address -- Physical mailing address of the payer.
Third-party disclosure consent
When you indicate that the payer or data controller is a different party, the wizard requires you to confirm a third-party disclosure consent checkbox. By checking this box, you confirm that you have the right to include the named third party's details in a public transparency notice. This consent is required before you can publish.
The data controller
The data controller is the person or organisation that determines the purposes and means of processing personal data in connection with the advertisement, as defined by the GDPR (Regulation 2016/679).
When do you need a separate data controller?
You need to identify a data controller if personal data is processed in connection with your ad. This includes scenarios where:
- You use a mailing list to send campaign emails.
- You target an ad based on demographics, interests, or behaviour on a platform.
- You collect data from respondents (for example, a survey linked in the ad).
In many cases, the sponsor is also the data controller. If so, check the "There is a data controller" box and enter the sponsor's details again, or simply note that the controller is identical to the sponsor.
If a separate entity controls the data processing -- for example, a political consultancy that manages your ad targeting -- enter that entity's details here.
Required fields (when a controller is specified)
- Name -- Full legal name of the data controller.
- Email -- Contact email for data subject requests.
- Postal address -- Physical mailing address.
The origin of funds
Step 4 also includes a mandatory free-text field for describing the origin of funds (Art. 9(1)(g) PAR). Here you describe, in plain language, where the money for this advertisement comes from. Examples:
- "Funded from the party's general campaign budget, sourced from membership fees and private donations."
- "Personally funded by the candidate from private savings."
- "Funded by the regional branch of the Green Party, derived from public party financing."
This field is always required, regardless of whether the payer differs from the sponsor.
Summary
| Role | Who is this? | Always required? |
|---|---|---|
| Sponsor | The entity that initiated the ad | Yes |
| Payer | The entity that paid for the ad | Only if different from sponsor |
| Data controller | The entity controlling personal data processing | Only if personal data is processed |
| Origin of funds | Description of where the money comes from | Yes |
If you are a candidate paying for your own simple print ad without any data processing, you only need to fill in the sponsor details and the funding origin. The payer and controller sections remain collapsed. For a more complex scenario -- say a party-funded online campaign managed by a consultancy -- all three roles may be different entities, and each must be identified clearly.