graz.at

Official website of Graz — 42 requests, 6 domains. A datareporter.eu CMP is present. But Siteimprove sends its tracking ping before the banner appears — while the policy explicitly names consent as the legal basis.

Timeline of the leak

+107 ms · datareporter CMP

webcachex-eu.datareporter.eu loads the CMP loader. Siteimprove loads in parallel with it.

+201 ms · Siteimprove

ssl.siteimprove.com/js/siteanalyze_89418.js — the script loads. The banner has not yet been shown.

+202 ms · datareporter banner

webcache-eu.datareporter.eu loads banner.css and banner.js — the banner is only starting to render.

+315 ms · datareporter ping

c.datareporter.eu — the banner-display event is recorded.

+361 ms · Siteimprove ping

89418.global.siteimproveanalytics.io — tracking with URL, referrer, title, resolution=1536x864. Before consent.

Indicators of GDPR non-compliance

GDPR Art. 6(1)(a), TKG § 165

Siteimprove loads at +201 ms and sends a tracking ping with the URL, referrer, and screen resolution at +361 ms. The datareporter.eu CMP initializes in parallel — the banner has not had time to appear. The policy explicitly names Art. 6(1)(a) as the legal basis for Siteimprove.

Context

Stadt Graz is Austria’s second-largest city. HAR: 42 requests, 6 domains. The privacy policy is detailed — with dedicated sections for Siteimprove, ArcGIS, Streamdiver, and social media.

A race between the CMP and the tracker

The datareporter.eu CMP and Siteimprove load nearly simultaneously — 94 ms apart. The CMP loads its banner (banner.css + banner.js) at +202 ms, while Siteimprove is already ready at +201 ms. The tracking ping goes out at +361 ms — at that point the banner is only just rendering, and the user hasn’t clicked anything yet. Stadt Graz’s policy states plainly: the legal basis is consent (Art. 6(1)(a)). The fact: tracking occurs before consent.

What the ping transmits

The request to 89418.global.siteimproveanalytics.io contains: the full page URL, the referrer, the page title (“Stadt Graz - Willkommen in Graz”), and the screen resolution (1536x864). This is enough to build a visitor profile even without cookies.

Conclusion

Graz is the third Austrian municipal portal, after Wien, to show the Siteimprove-before-consent pattern. The policy is correct, and the CMP is in place — but the technical implementation does not match the declared legal basis.

Evidence

Original (audit)

HAR file: at/graz-at-2026-05-26.har

SHA-256: 7e67399983e2d8f65e9276e093404761af696536667da40f50a95355f781b24d

Re-check snapshot

Awaiting changes

HAR files are stored on EU infrastructure (Proton Drive). SHA-256 is published for integrity verification.

Ready-to-send complaint letter

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

To: Datenschutzbehörde (DSB)
From: [Your name], [contact email]

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

2. Circumstances
I visited the website graz.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 loads at +201 ms and sends a tracking ping with the URL, referrer, and screen resolution at +361 ms. The datareporter.eu CMP initializes in parallel — the banner has not had time to appear. The policy explicitly names Art. 6(1)(a) as the legal basis for Siteimprove.

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

3. Provisions violated
GDPR Art. 6(1)(a), TKG § 165

4. Request
I request that you investigate the violations described and 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.

[Date]                                    [Signature / name]