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Technical audit · 13.05.2026

frontex.europa.eu

Frontex — European Border and Coast Guard Agency
EU-INSTITUTIONS

Policy changed — see what exactly · 2026-07-11 →

The EU's border agency — 23 domains, the most tracker-heavy site in the institutions series. YouTube fires at +0 ms. UA, retired in 2024, is still running. Google Ads appears on the site of an agency with no commercial activity.

Request timeline

+0 ms · first request
YouTube log_event — before the page even loads. Data goes to Google.
+224 ms · before the banner
Bootstrap CDN (jsDelivr), a cookie script, jQuery CDN, Cloudflare Turnstile, Twitter widgets — all simultaneously.
+226 ms · banner
A cookie script loads. It does not block the trackers.
+497 ms · before consent
Google Fonts — Montserrat and Roboto. USA.
+528 ms · before consent
GTM (GTM-K7BJHN6) — loads.
+633 ms · before consent
UA analytics.js — retired July 2024, still loading.
+690 ms · before consent
UA pageview collect — data goes to a discontinued service.
+815 ms
lens.frontex.europa.eu/piwik/piwik.js — Frontex's own Piwik, status 0 (blocked).
+2322 ms
Google Ads DoubleClick (pagead/id) — advertising infrastructure.

Declared versus actual

+ Google Analytics UA (discontinued) — not declared
+ Google Analytics GA4 — not declared
+ Google Ads / DoubleClick — not declared
+ YouTube (loaded directly) — not declared
+ Twitter / X widgets — not declared
+ Bootstrap CDN, jQuery CDN — not declared
+ Cloudflare Turnstile — not declared
+ Google Fonts — not declared

Transfer timings

+0 ms www.youtube.com

log_event before the page loads

+228 ms platform.twitter.com

Twitter widgets

+528 ms www.googletagmanager.com

GTM-K7BJHN6

+633 ms www.google-analytics.com

UA analytics.js — service discontinued in 2024

+2322 ms googleads.g.doubleclick.net

Google Ads pagead/id

Detected trackers

Indicators of GDPR non-compliance

Context

Frontex is the European Border and Coast Guard Agency, headquartered in Warsaw. It coordinates the protection of the EU’s external borders, conducts joint operations with member states, and processes data on individuals crossing the border. Governed by Regulation (EU) 2018/1725 and the specific Regulation (EU) 2019/1896. HAR: 131 requests, 23 domains.

The most tracker-heavy site in the institutions series

Against the backdrop of the European Parliament (2 domains), Europol (2 domains), the ECB (1 domain), and the Commission (5 domains) — Frontex, with 23 domains, stands out entirely. This is not technical carelessness — it reflects deliberate decisions: to integrate YouTube, Twitter, Google Ads, GTM.

YouTube at +0 ms — before the page loads

The first request in the HAR is www.youtube.com/youtubei/v1/log_event, at the +0 ms mark. This means the YouTube API initializes before the browser has even loaded the page’s HTML — the video was preloaded from a prior navigation or cached. View data goes to Google before any user interaction.

UA after retirement — again

As with ekel.ee and eua.eu — Frontex loads UA’s analytics.js (+633 ms) and sends a pageview collect (+690 ms). UA was retired as of July 2024. GA4 (G-Y2F9EGZV5D) runs in parallel. Two GA counters, one of them dead.

googleads.g.doubleclick.net/pagead/id (+2322 ms) is a Google advertising identifier, used to configure advertising audiences. Frontex is not a commercial organization and does not purchase Google advertising. The appearance of DoubleClick may mean it is configured within the GTM container and activates by default.

Piwik blocked

lens.frontex.europa.eu/piwik/piwik.js (+815 ms) — Frontex’s own Piwik instance, status 0 (connection blocked). Unlike EBA and eu-LISA, where Matomo operates correctly, Frontex’s self-hosted analytics is blocked, while external trackers run freely.

Sensitivity context

Frontex processes data on individuals crossing the EU’s external borders — including asylum data, border-crossing violations, and biometric data. The agency’s public website is visited by human rights advocates, journalists, researchers, and people who have filed complaints against the agency’s actions. Twitter widgets and Google Ads on such a site are architectural decisions warranting particular scrutiny.

Conclusion

23 domains, UA discontinued since 2024, Google Ads with no commercial purpose, YouTube with no consent, Twitter widgets — Frontex sits at the opposite pole from Europol and the ECB. All of this is wired through GTM — disabling GTM, or correctly configuring Consent Mode, would resolve most of these issues. A proprietary Piwik instance is already deployed — it just needs fixing, alongside the removal of the external trackers.

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/frontex-europa-eu-2026-05-13.har
SHA-256: f51e254a37ef1b11f779e0d66828eb414f0c806d65a65982d0b2c70995488169
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) — frontex.europa.eu

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 frontex.europa.eu.

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 YouTube log_event call (+0 ms) — the first request of the session, even before the page loads. GTM (+528 ms), UA (+633 ms), GA collect (+690 ms), Twitter widgets (+228 ms), Google Ads (+2322 ms) — all with no consent. A cookie-script loads at +226 ms but does not block the trackers.

2) Google Analytics UA was officially retired as of July 2024. UA's analytics.js loads and sends a pageview. Google Ads DoubleClick (pagead/id) — advertising infrastructure on the site of an agency with no commercial activity.


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/eu-frontex-europa-eu/

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 — frontex.europa.eu

1. Subject of the complaint
I am filing a complaint regarding the processing of my personal data by the website frontex.europa.eu.

2. Circumstances
I visited the website frontex.europa.eu and found indications that the processing of my personal data does not comply with the GDPR. The technical analysis published on gdpru.eu on 13 May 2026 (open methodology, reproducible measurements) documents the following indications:

1) The YouTube log_event call (+0 ms) — the first request of the session, even before the page loads. GTM (+528 ms), UA (+633 ms), GA collect (+690 ms), Twitter widgets (+228 ms), Google Ads (+2322 ms) — all with no consent. A cookie-script loads at +226 ms but does not block the trackers.

2) Google Analytics UA was officially retired as of July 2024. UA's analytics.js loads and sends a pageview. Google Ads DoubleClick (pagead/id) — advertising infrastructure on the site of an agency with no commercial activity.

Full technical documentation is published at: https://gdpru.eu/en/audits/eu-frontex-europa-eu/

3. GDPR provisions I ask you to examine
Regulation 2018/1725 Art. 5; Regulation 2018/1725 Art. 5 — additionally

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]