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Technical audit · 31.05.2026

denmark.dk

Official Portal About Denmark (Danish Ministry of Foreign Affairs)
DK

The official portal about Denmark (Ministry of Foreign Affairs) — 50 requests, 7 domains. The policy states that data is collected only with consent. In the capture, Silktide analytics loads and sends an events beacon prior to consent, even though a Cookiebot consent management platform is present. Silktide and the Cludo search service are not named in the policy text. The beacon is sent to a European Silktide endpoint.

Request timeline

+0 ms · portal load
Content and resources served from denmark.dk.
+162 ms · consent management platform
consent.cookiebot.eu — Cookiebot loads.
+163 ms · analytics script
analytics.silktide.com — the Silktide tracker loads, simultaneously with the consent management platform.
+235 ms · search service
customer.cludo.com/scripts/bundles/search-script.min.js — the Cludo site search script.
session state — no consent
Set-Cookie across the entire session is zero; no choice has been made by the user. The policy declares that data is collected only with consent.
+11236 ms · data transfer without consent
a.eu.silktide.com/v1/events/beacon — a Silktide POST event sent to a European endpoint, in the absence of consent.

Declared versus actual

✓ Data is collected when the visitor accepts cookies and gives consent ('as long as you consent') — declared
✓ Cookies are set upon clicking OK on the banner — declared
✓ Third parties are mentioned in generic terms (Facebook, Google); a separate PDF cookie list is provided — declared
+ Silktide Analytics — the actual analytics service, fires prior to consent, not named in the policy text — not declared
+ Cludo (customer.cludo.com) — a site search service, not named — not declared

Transfer timings

+163 ms analytics.silktide.com

Silktide — analytics script.

+235 ms customer.cludo.com

Cludo — site search service. Not named in the policy.

+11236 ms a.eu.silktide.com

Silktide events beacon (POST). European endpoint (AWS).

Detected trackers

Indicators of GDPR non-compliance

Context

denmark.dk is the official portal about Denmark, published by the Danish Ministry of Foreign Affairs (Udenrigsministeriet). It publishes material on Danish culture, society, design, and facts about the country for an international audience. The data controller is the Danish Ministry of Foreign Affairs. The current cookie policy was retrieved from the site. Capture: 50 requests, 7 domains, recorded in a clean browser.

Silktide (an events beacon to the European endpoint a.eu.silktide.com) — prior to consent.

Declared versus Actual

denmark.dk’s policy states its condition directly: data is collected when the visitor accepts cookies and gives consent, and cookies are set upon clicking OK on the banner. Third parties are mentioned in generic terms — Facebook and Google are given as examples, with a link provided to a separate PDF cookie list.

The capture shows an unnamed analytics service operating prior to consent. Simultaneously with the loading of the Cookiebot consent management platform (+162 ms), the Silktide script loads at +163 ms (analytics.silktide.com), and at +11236 ms a POST event is sent to a.eu.silktide.com/v1/events/beacon. The session state at this point is one of no consent: not a single cookie is set across the entire session, and no choice has been made by the user. A consent management platform is present but does not hold back Silktide analytics. In addition, at +235 ms, the Cludo site search script loads (customer.cludo.com). Neither Silktide nor Cludo is named by name in the policy text.

Thus, the actual collection of analytics data occurs prior to consent, which diverges from the policy’s own statement that data is collected only with consent, and the services actually in operation are not disclosed in the text.

The Silktide script loads at +163 ms; the event is sent at +11236 ms. Throughout the session, no consent was given (Set-Cookie is zero), yet analytics initialized and transmitted an event.

What Cannot Be Asserted from This Capture

The capture covers the home page. Silktide operates without cookies, and its beacon is sent to a European endpoint (AWS in the EU), so the question of cross-border transfer does not arise here; the subject of the discrepancy is the firing prior to consent, contrary to the policy’s statement, and the non-disclosure of the service in the text. In Danish practice, the supervisory authority has stated that it does not prioritize enforcement of consent requirements for simple first-party statistics — whether this applies to Silktide in this configuration is a matter for the competent authority to assess. The separate PDF cookie list referenced by the policy was not reviewed as part of this text check and does not disclose Silktide or Cludo; if they appear in that list, the review should be revisited accordingly. Server-side processing is not visible in a browser-based capture.

Conclusion

The official portal about Denmark states in its policy that data is collected only with the visitor’s consent, but Silktide analytics loads and sends an event prior to consent, even though a Cookiebot consent management platform is present on the site. Silktide and the Cludo search service are not named in the policy text. Silktide operates without cookies and transmits data to a European endpoint, which softens the transfer-related concern — but the discrepancy between the declared “only with consent” collection and the actual transmission of an event prior to consent, together with the non-disclosure of the services, indicates non-compliance with the requirements concerning consent and disclosure of recipients. Remedy: make Silktide’s firing conditional on the outcome of the Cookiebot choice (hold it back until consent is given), name Silktide and Cludo in the policy text, and bring the description of the consent model into line with actual behavior.

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: dk/denmark-dk-2026-05-31.har
SHA-256: b7d986889308a68487a6af772394ca8a68d632461766780fa36e7daae209dec9
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) — denmark.dk

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 denmark.dk.

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) denmark.dk's policy states that data is collected only when the visitor accepts cookies and gives consent ('as long as you consent'), and that cookies are set upon clicking OK on the banner. In the capture, the Silktide analytics service loads its script at +163 ms and sends an events beacon (a POST request to a.eu.silktide.com/v1/events/beacon) at +11236 ms in a state of no consent: Set-Cookie across the entire session is zero, and no choice has been made by the user. A Cookiebot consent management platform is present, but it does not hold back Silktide. The transfer of data occurs prior to consent, contrary to the policy's own statement.

2) The policy mentions third parties in generic terms (Facebook, Google) and refers to a separate PDF cookie list, but does not name the services actually in operation — the Silktide analytics tool and the Cludo search service (customer.cludo.com) — by name in the text.


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/dk-denmark-dk/

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: Danish Data Protection Agency (Datatilsynet) — 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 — denmark.dk

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

2. Circumstances
I visited the website denmark.dk and found indications that the processing of my personal data does not comply with the GDPR. The technical analysis published on gdpru.eu on 31 May 2026 (open methodology, reproducible measurements) documents the following indications:

1) denmark.dk's policy states that data is collected only when the visitor accepts cookies and gives consent ('as long as you consent'), and that cookies are set upon clicking OK on the banner. In the capture, the Silktide analytics service loads its script at +163 ms and sends an events beacon (a POST request to a.eu.silktide.com/v1/events/beacon) at +11236 ms in a state of no consent: Set-Cookie across the entire session is zero, and no choice has been made by the user. A Cookiebot consent management platform is present, but it does not hold back Silktide. The transfer of data occurs prior to consent, contrary to the policy's own statement.

2) The policy mentions third parties in generic terms (Facebook, Google) and refers to a separate PDF cookie list, but does not name the services actually in operation — the Silktide analytics tool and the Cludo search service (customer.cludo.com) — by name in the text.

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

3. GDPR provisions I ask you to examine
ePrivacy (Danish Cookiebekendtgørelse) + the policy's own stated rule; GDPR Art. 13(1)(e) — disclosure of recipients

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]