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Technical audit · 31.05.2026

erhvervsstyrelsen.dk

Danish Business Authority
DK

Policy changed — see what exactly · 2026-10-03 →

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.

Request timeline

+0 ms · portal load
Content and resources served from erhvervsstyrelsen.dk.
+107 ms · analytics script
siteimproveanalytics.com/js/siteanalyze_273738.js — the Siteimprove tracker loads.
session state — no consent
No consent management platform is detected on the site. Set-Cookie across the entire session is zero; no choice has been made by the user.
+464 ms · data transfer without consent
273738.global.siteimproveanalytics.io/image.aspx — the Siteimprove beacon transmits the URL, page title, screen resolution, and a persistent visitor identifier (luid).

Declared versus actual

✓ Data is used 'in anonymized form for statistics' — declared
✓ The policy's cookie table: Intercom and others (Siteimprove is absent) — declared
+ Siteimprove Analytics — the actual analytics service, not named in the policy; fires prior to consent, carries a persistent visitor identifier and screen resolution — not declared
+ No consent management platform is detected on the site — not declared

Transfer timings

+107 ms siteimproveanalytics.com

Siteimprove siteanalyze_273738.js. Analytics script.

+464 ms 273738.global.siteimproveanalytics.io

Siteimprove beacon. URL + page title + screen resolution + visitor identifier.

Detected trackers

Indicators of GDPR non-compliance

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.

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.

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 indicate non-compliance with 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.

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/erhvervsstyrelsen-dk-2026-05-31.har
SHA-256: de73bd777f2b2be2fe81669049223544fefa5eaf6cf421be60853deb4ac51975
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) — erhvervsstyrelsen.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 erhvervsstyrelsen.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) 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.


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-erhvervsstyrelsen-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 — erhvervsstyrelsen.dk

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. GDPR provisions I ask you to examine
GDPR Art. 13(1)(e) — disclosure of recipients; ePrivacy (Danish Cookiebekendtgørelse) + Art. 5(1)(a) — consent and anonymity

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]