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Technical audit · 26.05.2026

schule.at

Austria's Official Educational Platform
AT

Austria's official educational platform — 58 requests, 3 domains. Piwik on tracking.edugroup.at fires without consent. YouTube receives the IP address via video previews. The policy describes Google Analytics — absent from the HAR, while an undeclared Piwik is present instead.

Request timeline

+232 ms · YouTube preview
img.youtube.com loads previews for three videos. A connection to YouTube is established with no action from the user.
+373 ms · Piwik
tracking.edugroup.at/piwik.js loads without consent.
+425 ms · tracking ping
tracking.edugroup.at/piwik.php — a POST with action_name and idsite=20. Before consent.
Session total
Google Analytics did not appear in the HAR. 53 requests to www.schule.at, 3 to img.youtube.com, 2 to tracking.edugroup.at.

Declared versus actual

✓ Google Analytics — described in the policy with an opt-out scheme, absent from the HAR — declared
+ Piwik/Matomo on tracking.edugroup.at — not mentioned in the policy — not declared
+ YouTube img.youtube.com — loading previews without click-to-load is not mentioned — not declared

Transfer timings

+232 ms img.youtube.com

3 video previews loaded directly. IP address sent to Google without consent.

+373 ms tracking.edugroup.at

Piwik script. A subdomain of Education Group GmbH (Linz).

+425 ms tracking.edugroup.at

Tracking ping: idsite=20, without consent.

Detected trackers

Indicators of GDPR non-compliance

Context

schule.at is Austria’s official digital educational platform, operated by Education Group GmbH (Linz) on behalf of the BMBWF (Bundesministerium für Bildung, Wissenschaft und Forschung). HAR: 58 requests, 3 domains.

Piwik without declaration

tracking.edugroup.at — Piwik/Matomo on Education Group’s infrastructure, fires at 373 ms. The privacy policy describes Google Analytics with a detailed cookie table and an opt-out link — but Piwik is never mentioned. Google Analytics did not appear in the HAR: it may already be disabled, but the policy has not been updated to reflect this.

YouTube without a click

Three YouTube videos are embedded via direct preview loading from img.youtube.com — without click-to-load. The visitor’s IP address goes to Google on every page load, regardless of whether the user wants to watch the video.

Sensitive context

schule.at is an educational platform for children and teachers. Minors are among its visitors. Tracking without consent and data transfer to YouTube are especially sensitive in this context.

Conclusion

The platform declared a tool that isn’t in the HAR, and failed to declare the one that is actually running. YouTube receives data without a click. For an educational portal with a young audience, this is precisely the set of issues that should be fixed first.

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/schule-at-2026-05-26.har
SHA-256: 63b4017c475eab8cd6bf6203547beb06947c432a25932f47bb5bdbd668079295
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) — schule.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 schule.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) tracking.edugroup.at/piwik.js loads at 373 ms and sends a tracking ping at 425 ms — without consent. The policy describes Google Analytics with an opt-out scheme; Piwik is not mentioned at all.

2) img.youtube.com loads previews for three videos directly, without click-to-load. YouTube receives the IP address on every page load with no action from the user.


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-schule-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 — schule.at

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

2. Circumstances
I visited the website schule.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) tracking.edugroup.at/piwik.js loads at 373 ms and sends a tracking ping at 425 ms — without consent. The policy describes Google Analytics with an opt-out scheme; Piwik is not mentioned at all.

2) img.youtube.com loads previews for three videos directly, without click-to-load. YouTube receives the IP address on every page load with no action from the user.

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

3. GDPR provisions I ask you to examine
GDPR Art. 6(1)(a), Art. 13, TKG § 165; GDPR Art. 6(1)(a)

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]