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Technical audit · 26.05.2026

belga.be

Belgian National News Agency
BE

Belgium's national news agency — 79 requests, 18 domains. A full advertising and analytics stack — Google Ads and GA4, LinkedIn Ads, Contentsquare session recording, Lead Forensics IP identification, Sentry — fires before consent. The CookieYes consent manager loads after the trackers have started and does not hold them back. Not a single service is named in the policy.

Request timeline

+0 ms · portal load
Content served from belga.be and the first-party backend www-bo.belga.be.
+497 ms · Google Tag Manager
www.googletagmanager.com — the tag container, launching Google Ads (AW-1005663691) and GA4 (G-X90HZ8CS30).
+531–550 ms · LinkedIn and Sentry
snap.licdn.com — LinkedIn Insight; o4505089785921536.ingest.sentry.io — Sentry error monitoring.
+686 ms · consent manager (delayed)
cdn-cookieyes.com — CookieYes loads after the trackers have already started and does not hold them back.
session state — no consent
Zero Set-Cookie headers for the entire session; no user choice was made.
+858–1197 ms · advertising and session recording
Contentsquare (t.contentsquare.net, c.ba.contentsquare.net); Google ccm/collect page_view with auid; LinkedIn Ads px.ads.linkedin.com (pid 4472417).
+1419–1454 ms · GA4 and IP identification
region1.google-analytics.com/g/collect (GA4, cid); secure.leadforensics.com/Track/Capture.aspx (B2B identification, account 97305).

Declared versus actual

✓ The policy mentions cookies (repeatedly) and consent in general terms, advertising only in passing — declared
✓ No specific services or third-party recipients are named — declared
+ Google Ads + GA4 + GTM — advertising and analytics, before consent, not named — not declared
+ LinkedIn Ads (px.ads.linkedin.com) — advertising, before consent, not named — not declared
+ Contentsquare — session recording/behavior, before consent, not named — not declared
+ Lead Forensics — IP-based identification, before consent, not named — not declared
+ Sentry, CookieYes, Whizeo — not named — not declared

Transfer timings

+878 ms www.google.com

ccm/collect page_view with an advertising identifier (auid). Google Ads AW-1005663691, USA.

+1197 ms px.ads.linkedin.com

LinkedIn Ads attribution/collect, pid 4472417. USA.

+1131 ms c.ba.contentsquare.net

Contentsquare pageview — behavior recording (uu).

+1419 ms region1.google-analytics.com

GA4 g/collect page_view (cid). G-X90HZ8CS30.

+1454 ms secure.leadforensics.com

Lead Forensics — visitor identification by IP. Account 97305.

Detected trackers

Indicators of GDPR non-compliance

Context

belga.be is the website of Belga News Agency, Belgium’s national news agency and a news supplier to the country’s media. Controller: Belga News Agency NV. The privacy policy is relatively short (roughly 5,700 characters). Measurement: 79 requests, 18 domains, captured on a clean browser.

Google, LinkedIn, Contentsquare, Lead Forensics, Sentry.

Declared versus actual

Belga’s policy repeatedly mentions cookies, and refers to consent and third parties in general terms, touching on advertising only in passing. It names not a single specific measurement, advertising, or identification service.

The measurement reveals an extensive stack that fires before consent. The load order is telling: advertising and analytics services start before the consent manager even appears. Google Tag Manager (+497 ms) launches Google Ads (AW-1005663691) and GA4 (G-X90HZ8CS30); the endpoint www.google.com/ccm/collect receives a page_view event four times, carrying the title “Belga - Homepage,” the page address, and an advertising identifier (auid), while region1.google-analytics.com/g/collect receives a GA4 event with a client identifier (cid). Running in parallel: LinkedIn Ads (snap.licdn.com and px.ads.linkedin.com, pid 4472417), Contentsquare’s session and behavior recording service (t.contentsquare.net, c.ba.contentsquare.net), Sentry error monitoring, and — separately significant — Lead Forensics (secure.leadforensics.com/Track/Capture.aspx, account 97305), a service that de-anonymizes corporate visitors by IP address.

The CookieYes consent manager only loads at +686 ms — that is, after some of the trackers have already started — and does not hold them back in the measurement: not a single cookie is set for the entire session, no user choice is made, and yet the services fire anyway. None of the listed services — Google, LinkedIn, Contentsquare, Lead Forensics, Sentry, CookieYes — is named in the policy. A number of requests to whizeo.com domains relate to Belga’s news content platform; their role as a tracking mechanism is not separately established and is not treated as grounds for a violation.

Trackers start at +497 ms, the consent manager at +686 ms, and data-transmitting events continue through +4456 ms. The load order is such that consent could not technically have preceded the firing of advertising and analytics; and in fact, no consent was given during the session (zero Set-Cookie).

What cannot be claimed from the measurement

The measurement covers the homepage. Visitor identifiers (auid, cid, the Contentsquare identifier) are not fully reproduced in this publication; service account identifiers (AW-1005663691, G-X90HZ8CS30, LinkedIn pid 4472417, Lead Forensics 97305) belong to the site’s configuration, not to the visitor. The role of the Whizeo platform is attributed to news content delivery. Google, LinkedIn, and Contentsquare may use edge nodes within the EU, so the conclusion is drawn based on the recipients’ affiliation. Server-side processing is not visible in a browser-based measurement.

Conclusion

The website of Belgium’s national news agency launches a full commercial stack before consent: Google Ads and LinkedIn Ads advertising, GA4 analytics, Contentsquare session recording, Sentry monitoring, and — most sensitively — visitor identification by IP via Lead Forensics. A CookieYes consent manager is present on the site, but loads after the trackers have started and does not hold them back, and not a single service is named in the policy. The combination of advertising and identification services firing before consent, data transfer to recipients in the USA, and the complete absence of their disclosure indicates non-compliance with the requirements for prior consent, disclosure of recipients, and cross-border transfer. Remedy: switch CookieYes to genuine blocking mode so that all non-technical services are held back until consent; prevent Google, LinkedIn, Contentsquare, and Lead Forensics from firing before the user’s choice; disclose all actually used services in the policy.

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: be/belga-be-2026-05-26.har
SHA-256: 924ebfd9ad07d219dc3e64db18d1fd08e48f18335333ab08861409c83e3fb781
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) — belga.be

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 belga.be.

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) The CookieYes consent manager loads at +686 ms — after the advertising and analytics services have already started — and does not hold them back. Before consent, the following fire: Google Tag Manager with Google Ads (AW-1005663691) and GA4 (G-X90HZ8CS30), sending a page_view event 'Belga - Homepage' with an advertising identifier (auid) and a client identifier (cid); LinkedIn Ads (snap.licdn.com and px.ads.linkedin.com, pid 4472417); Contentsquare (session and behavior recording); Lead Forensics (B2B visitor identification by IP, account 97305); Sentry. Zero Set-Cookie headers for the entire session — no user choice was made.

2) Belga's policy mentions cookies and consent in general terms, but names not a single actual service: not Google, not LinkedIn, not Contentsquare, not Lead Forensics, not Sentry, not even the CookieYes consent manager itself. Data recipients are not disclosed.

3) Before consent, data is transmitted to recipients outside the EU: the page_view event, advertising identifier, and client identifier go to Google (USA); advertising events go to LinkedIn (USA); behavioral data goes to Contentsquare; IP-based identification goes to Lead Forensics. The transfer occurs without consent.

4) Lead Forensics specializes in de-anonymizing corporate visitors by IP address (endpoint Track/Capture.aspx, account 97305). On the website of a national news agency, this allows visits — including those of journalists and organizations — to be linked to specific companies, before consent and without disclosure.


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/be-belga-be/

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: Autorité de protection des données (APD) — 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 — belga.be

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

2. Circumstances
I visited the website belga.be 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) The CookieYes consent manager loads at +686 ms — after the advertising and analytics services have already started — and does not hold them back. Before consent, the following fire: Google Tag Manager with Google Ads (AW-1005663691) and GA4 (G-X90HZ8CS30), sending a page_view event 'Belga - Homepage' with an advertising identifier (auid) and a client identifier (cid); LinkedIn Ads (snap.licdn.com and px.ads.linkedin.com, pid 4472417); Contentsquare (session and behavior recording); Lead Forensics (B2B visitor identification by IP, account 97305); Sentry. Zero Set-Cookie headers for the entire session — no user choice was made.

2) Belga's policy mentions cookies and consent in general terms, but names not a single actual service: not Google, not LinkedIn, not Contentsquare, not Lead Forensics, not Sentry, not even the CookieYes consent manager itself. Data recipients are not disclosed.

3) Before consent, data is transmitted to recipients outside the EU: the page_view event, advertising identifier, and client identifier go to Google (USA); advertising events go to LinkedIn (USA); behavioral data goes to Contentsquare; IP-based identification goes to Lead Forensics. The transfer occurs without consent.

4) Lead Forensics specializes in de-anonymizing corporate visitors by IP address (endpoint Track/Capture.aspx, account 97305). On the website of a national news agency, this allows visits — including those of journalists and organizations — to be linked to specific companies, before consent and without disclosure.

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

3. GDPR provisions I ask you to examine
ePrivacy (Belgian implementation) + GDPR Art. 6(1) — trackers before consent; GDPR Art. 13(1)(e) — disclosure of recipients; GDPR Chapter V — cross-border transfer; Distinctive nature — IP-based identification

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]