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Technical audit · 09.05.2026

ccdcoe.org

NATO Cooperative Cyber Defence Centre of Excellence, Tallinn
EU-INSTITUTIONS

The center that develops NATO's rules of cyber warfare and the Tallinn Manual on international cyber law has Google Analytics and Cloudflare Insights wired into its own site's code. Both are blocked by the CSP — no data got out. But they are configured in and attempt to load nine times per session. No privacy policy exists at all.

Request timeline

On load
Cloudflare Insights and Google Analytics initiate requests on every navigation — 9 times per session each, in sync. All return status 0 — blocked by the CSP.
Consent banner
Absent. Zero consent requests, zero Set-Cookie. And there is no privacy policy on the site at all — neither a Privacy Policy nor a Cookie Policy.
Session total
No data left the site anywhere. Of 281 requests, 263 go to ccdcoe.org's own server. No Google Fonts, no external CDN, no ad networks. The CSP holds.

Declared versus actual

+ Google Analytics — wired into the code, blocked by the CSP — not declared
+ Cloudflare Insights — wired into the code, blocked by the CSP — not declared
+ No privacy policy exists whatsoever — not declared

Transfer timings

No exact timing

on load www.google-analytics.comWired into the code, 9 attempts per session, each returning status 0
on load static.cloudflareinsights.comWired into the code, 9 attempts, status 0. No data left

Detected trackers

Indicators of GDPR non-compliance

Context

CCDCOE is NATO’s Cooperative Cyber Defence Centre of Excellence, headquartered in Tallinn. It develops the Tallinn Manual on international law applicable to cyberspace, trains military cyber-defense specialists from NATO countries, and runs Locked Shields — the world’s largest cyber-defense exercise.

What is done correctly

Of 281 requests, 263 go to ccdcoe.org’s own server — all infrastructure is local. No external fonts, no external CDN, no advertising networks. Both external trackers are blocked: static.cloudflareinsights.com (9 requests, status 0) and www.google-analytics.com (9 requests, status 0). The CSP works — no data reached either Cloudflare or Google. Technically, there is no transfer violation.

An uncomfortable truth

Google Analytics and Cloudflare Insights are wired into the site’s code — both of them. And they attempt to load on every navigation, 9 times per session each, in sync. This is the same architectural situation seen at kapo.ee: the tools are configured, but the CSP blocks them. Someone made the decision to add these trackers to the code. The CSP made a different decision — to block them. If the security policy is ever relaxed or changed during a site update, both trackers would start working instantly, because they are already wired in and waiting.

No privacy policy exists

ccdcoe.org has no public privacy document — no Privacy Policy page, no Cookie Policy, no footer section. Meanwhile, two trackers are wired into the code and attempt to load on every visit. GDPR applies to this international NATO military organization in a particular way: it has immunity from Estonian national law, and its regulator is not the AKI. But GDPR as an EU regulation is technically applicable to processing EU citizens’ data, and the absence of any information about that processing is a transparency gap.

Conclusion

CCDCOE develops the rules of cyber warfare for NATO, trains people to defend critical infrastructure from cyberattacks, runs Locked Shields, and publishes the Tallinn Manual — effectively the bible of international cyber law. And on its own website, Google Analytics and Cloudflare Insights are wired into the code and attempt to load nine times per session, while no privacy policy exists at all. Nine attempts, nine times returning status 0 — the CSP holds, no data got out. The Tallinn Manual describes how states should behave in cyberspace. The site’s own story is different: no data left, but the intent is documented in the code.

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: eu/ccdcoe-org-2026-05-09.har
SHA-256: 8c688eff3a6aac39dde6f2d5143265504a306a7496e67858caab6f478c3528db
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) — ccdcoe.org

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 ccdcoe.org.

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) No privacy policy exists as a public document — no Privacy Policy, no Cookie Policy, no footer section. At the same time, two trackers are wired into the code and attempt to load on every visit.

2) Google Analytics and Cloudflare Insights are wired into the site's code. Both are blocked by the CSP (status 0), but the architecture contains tools for transmitting data to the USA.


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/ccdcoe-org/

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: European Data Protection Supervisor (EDPS) — edps.europa.eu

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 — ccdcoe.org

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

2. Circumstances
I visited the website ccdcoe.org and found indications that the processing of my personal data does not comply with the GDPR. The technical analysis published on gdpru.eu on 9 May 2026 (open methodology, reproducible measurements) documents the following indications:

1) No privacy policy exists as a public document — no Privacy Policy, no Cookie Policy, no footer section. At the same time, two trackers are wired into the code and attempt to load on every visit.

2) Google Analytics and Cloudflare Insights are wired into the site's code. Both are blocked by the CSP (status 0), but the architecture contains tools for transmitting data to the USA.

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

3. GDPR provisions I ask you to examine
GDPR Art. 13, Art. 12; GDPR Art. 5(1)(f)

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]