Policy changed — see what exactly · 2026-08-05 →
The Danish Business Authority — 41 requests, 3 domains. The Siteimprove analytics service fires prior to consent and without a consent management platform, transmitting the URL, page title, screen resolution, and a persistent visitor identifier. Siteimprove is not named in the policy, and the data is declared to be used in anonymized form.
Timeline of the leak
Declared versus actual
Transfer timings
Siteimprove siteanalyze_273738.js. Analytics script.
Siteimprove beacon. URL + page title + screen resolution + visitor identifier.
Detected trackers
- Siteimprove Analytics (siteimproveanalytics.com, siteimproveanalytics.io)
Indicators of GDPR non-compliance
- GDPR Art. 13(1)(e) — disclosure of recipientsThe capture shows the Siteimprove analytics service running: the script siteimproveanalytics.com/js/siteanalyze_273738.js (+107 ms) and data collection at 273738.global.siteimproveanalytics.io (+464 ms). The policy contains a cookie table (Intercom and others) and mentions statistics, but Siteimprove is not named in it. The actual recipient of the analytics data is not disclosed.
- ePrivacy (Danish Cookiebekendtgørelse) + Art. 5(1)(a) — consent and anonymitySiteimprove fires prior to consent: no consent management platform is present on the site, and Set-Cookie across the entire session is zero. The image.aspx beacon transmits the page URL, page title, screen resolution (1536x864), and a persistent visitor identifier (luid). The policy declares that data is used 'in anonymized form for statistics'; a persistent identifier and screen resolution are identifying parameters, which diverges from the declared anonymity.
Context
erhvervsstyrelsen.dk is the official website of the Danish Business Authority (Erhvervsstyrelsen), the body responsible for business regulation, company registration, and supervision. The data controller is the agency. The privacy policy is approximately 8,700 characters and contains a cookie table. Capture: 41 requests, 3 domains, recorded in a clean browser.
Direct Recipients of Data (prior to consent)
Siteimprove — the page URL, page title, screen resolution, and a persistent visitor identifier (luid).
Declared versus Actual
The policy describes statistical processing in general terms: data is used in anonymized form for statistical purposes. The cookie table lists individual services (such as Intercom), but the Siteimprove analytics tool is not named in the policy.
The capture shows Siteimprove specifically in operation. At +107 ms, the script siteimproveanalytics.com/js/siteanalyze_273738.js loads, and at +464 ms a beacon is sent to 273738.global.siteimproveanalytics.io/image.aspx. The beacon transmits the page URL, its title, screen resolution (1536x864), and a persistent visitor identifier (luid). No consent management platform is detected on the site, no cookies are set across the entire session, and no choice has been made by the user — meaning the transfer occurs prior to consent. A persistent visitor identifier and screen resolution are parameters that allow the device to be recognized, which diverges from the anonymous form of statistics declared in the policy. Siteimprove itself is not disclosed in the policy.
Timing Relative to Consent
The Siteimprove script loads at +107 ms; the beacon carrying the data at +464 ms. No consent mechanism is present in the capture; analytics fires immediately, before any choice is made by the user (Set-Cookie is zero).
What Cannot Be Asserted from This Capture
The capture covers the home page. Siteimprove is often positioned as privacy-conscious analytics; whether an exemption from consent applies to it despite the transmission of a persistent identifier and screen resolution is a matter for the competent authority to decide. This review was conducted against the policy provided, which contains a cookie table; if a separate, current cookie declaration exists, the review should be supplemented accordingly. The visitor identifier is not reproduced in full in this publication. Server-side processing is not visible in a browser-based capture.
Conclusion
The Danish Business Authority uses Siteimprove analytics, which fires prior to consent and without a consent management platform, transmitting the URL, page title, screen resolution, and a persistent visitor identifier. The Siteimprove service is not named in the policy, and the data is declared to be used in anonymized form — which diverges from the transmission of identifying parameters. For the website of a government body, the non-disclosure of the actual analytics service and its firing with a visitor identifier prior to consent constitute a violation of the requirements concerning disclosure of recipients and consent for statistics. Remedy: name Siteimprove in the policy, make its firing conditional on consent (implement a consent management platform that holds back analytics until a choice is made), and bring the description of the processing into line with the parameters actually transmitted.
de73bd777f2b2be2fe81669049223544fefa5eaf6cf421be60853deb4ac51975Where to file: Danish Data Protection Agency (Datatilsynet) — file a complaint online →
To: Danish Data Protection Agency (Datatilsynet) From: [Your name], [contact email] 1. Subject of the complaint I am filing a complaint regarding the processing of my personal data by the website erhvervsstyrelsen.dk. 2. Circumstances I visited the website erhvervsstyrelsen.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) The capture shows the Siteimprove analytics service running: the script siteimproveanalytics.com/js/siteanalyze_273738.js (+107 ms) and data collection at 273738.global.siteimproveanalytics.io (+464 ms). The policy contains a cookie table (Intercom and others) and mentions statistics, but Siteimprove is not named in it. The actual recipient of the analytics data is not disclosed. 2) Siteimprove fires prior to consent: no consent management platform is present on the site, and Set-Cookie across the entire session is zero. The image.aspx beacon transmits the page URL, page title, screen resolution (1536x864), and a persistent visitor identifier (luid). The policy declares that data is used 'in anonymized form for statistics'; a persistent identifier and screen resolution are identifying parameters, which diverges from the declared anonymity. Full technical documentation is published at: https://gdpru.eu/en/audits/dk-erhvervsstyrelsen-dk/ 3. Provisions violated GDPR Art. 13(1)(e) — disclosure of recipients; ePrivacy (Danish Cookiebekendtgørelse) + Art. 5(1)(a) — consent and anonymity 4. Request I request that you investigate the violations described and 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. [Date] [Signature / name]