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Technical audit · 26.05.2026

bmj.gv.at

Austrian Federal Ministry of Justice
AT

Federal Ministry of Justice — 39 requests, 3 domains. Siteimprove Analytics loads without consent at +2671 ms. Matomo is declared — absent from the HAR. The policy names both tools, but there is no consent mechanism.

Request timeline

+2671 ms · Siteimprove
siteimproveanalytics.com/js/siteanalyze_6036590.js loads without consent. There is no banner.
Session total
39 requests. 36 — [www.bmj.gv.at](https://www.bmj.gv.at), 2 — bmj.gv.at (redirects), 1 — siteimproveanalytics.com. Matomo did not appear in the HAR.

Declared versus actual

✓ Siteimprove Analytics — declared, servers in Denmark, appears in the HAR before consent — declared
✓ Matomo — declared, absent from the HAR — declared

Transfer timings

+2671 ms siteimproveanalytics.com

Cookieless tracking based on a Visitor Hash. Data on servers in Denmark.

Detected trackers

Indicators of GDPR non-compliance

Context

Bundesministerium für Justiz (BMJ) is the federal ministry of justice, overseeing the judicial system and the prison service. HAR: 39 requests, 3 domains. The same BRZ platform, Magnolia CMS.

Siteimprove is declared in the policy — that’s a plus. But it loads at +2671 ms without any consent banner. The policy describes cookies and analytics without stating a legal basis and without providing for opt-in. Matomo is also declared, but did not appear in the HAR — possibly because a consent gate is configured for it but not for Siteimprove.

Notable context

bmj.gv.at is the ministry responsible for justiz.gv.at (the judicial system portal). justiz.gv.at showed a clean HAR. bmj.gv.at — the ministry’s own site — uses Siteimprove without consent. Different architectural choices within the same ministry.

Conclusion

The Ministry of Justice declares its analytics — and that’s correct. But Siteimprove runs before consent. The same pattern seen at the Sozialministerium and bildung.gv.at — Siteimprove on Austrian government sites consistently fires without a consent gate.

Evidence

How to verify: download the file and compute its checksum — sha256sum file.har (Linux, macOS) or certutil -hashfile file.har SHA256 (Windows); it must match the one shown. The conclusions apply to the scope of this measurement — see the limitations of the method.

Original (audit)
HAR file: at/bmj-gv-at-2026-05-26.har
SHA-256: ce2ac29d2c76d74fe8820301a3780b39c7dc758840d7b6a93fa66a573ee84305
Re-check snapshot
Awaiting changes
HAR files are stored on EU infrastructure (Proton Drive). SHA-256 is published for integrity verification.
Want a response from the company about this audit? → Open the tool

Fill in once — it will be inserted into every letter below:

All fields are required to print the document — this is a formal requirement of the letter itself (the particulars of an official submission), not data collection: nothing is sent or saved anywhere, it all stays in your browser and disappears when you close the page. See the methodology for details.

Step 1. Data access request (GDPR Art. 15)

Send this letter directly to the company first — before contacting the regulator it has the right to respond (GDPR Art. 12(3) — 30 days).

Subject: Data access request (GDPR Art. 15) — bmj.gv.at

To: [insert the company's address — DPO / support / legal department]
From: [Your name], [contact email]

I request access to my personal data processed in connection with the website bmj.gv.at.

1. Categories of data and purposes of processing (Art. 15(1)(a)-(c))
Based on an independent technical analysis of the site, I request confirmation and detailed disclosure of the following categories of processing:

1) Siteimprove Analytics loads 2671 ms after the page opens — without a consent banner and without consent. The privacy policy declares Siteimprove but does not state a legal basis and does not provide for opt-in.


2. Recipients, retention periods, and transfers outside the EEA (Art. 15(1)(c)-(d), 46)
I also request the full list of third-party recipients, the applicable retention period for each category, and the legal basis for any transfer of data outside the EEA. The full technical audit with evidence (saved network log, SHA-256 checksum) is published at: https://gdpru.eu/en/audits/at-bmj-gv-at/

3. Automated processing and profiling (Art. 15(1)(h))
Please state whether I am subject to automated decision-making or profiling, and if so, disclose the logic involved.

Sincerely,

[Your name]
[contact email]
[Country]


[Date]
IMPORTANT: before filing a complaint with the regulator, first contact the company directly and give it 30 days to respond. Without this step the regulator may reject the complaint. Details and a template letter to the company are in the Methodology.
Ready-to-send complaint letter

Where to file: Datenschutzbehörde (DSB) — file a complaint online →

The regulator reviews complaints in its national language. There is an officially translated template from the European Data Protection Board (EDPB) — you can use it instead of or alongside this letter: Official EDPB complaint form (PDF, your language)

Subject: Complaint regarding personal data processing — bmj.gv.at

1. Subject of the complaint
I am filing a complaint regarding the processing of my personal data by the website bmj.gv.at.

2. Circumstances
I visited the website bmj.gv.at and found indications that the processing of my personal data does not comply with the GDPR. The technical analysis published on gdpru.eu on 26 May 2026 (open methodology, reproducible measurements) documents the following indications:

1) Siteimprove Analytics loads 2671 ms after the page opens — without a consent banner and without consent. The privacy policy declares Siteimprove but does not state a legal basis and does not provide for opt-in.

Full technical documentation is published at: https://gdpru.eu/en/audits/at-bmj-gv-at/

3. GDPR provisions I ask you to examine
GDPR Art. 6(1)(a), TKG § 165

4. Request
I request that you examine the circumstances described and, if non-compliance is confirmed, apply the measures provided for in Article 58(2) GDPR.

5. Attachments
The full evidence base — the HAR file, its SHA-256 checksum and the quotation from the site's privacy policy documenting the stated contradiction — is published and verifiable at the link in point 2 above.

Sincerely,

[Your name]
[contact email]
[Country]


[Date]