Shifting Battlegrounds: Corporate Political Activity in the General Data Protection Regulation

The impressive body of literature on corporate political activity (CPA) has remained largely silent on the substance of information strategies that firms utilize to influence policymakers. To address this deficiency, our study is situated in the European Union (EU), where political scientists have noted information strategies to be central to achieving lobbying success; the EU also provides a context of global norm-setting activities, especially with its General Data Protection Regulation (GDPR). Aided by recent advances in the field of unsupervised machine learning, we performed a structural topic model analysis of the entire set of lobby documents submitted during two GDPR consultations, which were obtained via a freedom of information request. Our analysis of the substance of information strategies reveals that the two policy phases reveal ‘shifting battlegrounds’, where firms first seek to influence what is included and excluded in the legislation, after which they engage the interests of other stakeholders. We thus identify two distinct information (sub)strategies, and point at the need for more attention for institutional procedures and for the role of other stakeholders’ lobbying activities in CPA research.