denmark.dk

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.

Direct Recipients of Data (prior to consent)

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.

Timing Relative to Consent

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, constitutes a violation of 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.