Abstract For the most part, privacy and data protection laws arose not through grassroots pressure but through interactions between governmental and business elites in the context of broader international harmonization efforts. Thus, civil society activists have rarely been seen as a client constituency with equivalent weight to governmental and business interests. There is evidence, however, that the privacy advocacy network is becoming more influential in comparative context. In most countries, a network of advocates has emerged with a relatively distinct profile from the “official” data protection authorities. Individual advocates play several conflicting roles and often exist within groups with wider civil liberties, human rights, digital rights, or consumer interests. Those at the center of the privacy advocacy network possess a set of core beliefs about the importance of privacy, and as one passes to the outer edges the issue becomes more and more peripheral. Privacy advocacy is beginning to occur f...