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Technical audit · 31.05.2026

courts.ie

Courts Service of Ireland — the administrative body of the Irish court system
IE

The Courts Service of Ireland — 32 requests, 7 domains. GTM and Hotjar load simultaneously, before the site's own cookie manager. Hotjar records visitor behavior on the courts service's site without consent.

Request timeline

+195 ms · CMP
courts.ie/cookies-manager.js — the site's own cookie manager. Does not block trackers.
+210 ms · prior to consent
GTM (GTM-5GT3G58P) and Hotjar (hotjar-3260934.js) — simultaneously, without consent.
+216 ms · prior to consent
Google Fonts — Material Symbols. IP address to Google, USA.
+5351 ms
GA4 collect (G-QZ4BZPW2JP) — visit data. USA.

Declared versus actual

✓ YouTube privacy-enhanced mode — mentioned in the policy — declared
+ Hotjar — not declared
+ Google Fonts (Material Symbols) — not declared

Transfer timings

+210 ms www.googletagmanager.com

GTM-5GT3G58P

+210 ms static.hotjar.com

Hotjar session recording — without consent

+5351 ms region1.google-analytics.com

GA4 collect

Detected trackers

Indicators of GDPR non-compliance

Context

The Courts Service of Ireland is the state body responsible for the operation of Ireland’s courts. It manages court registers, publishes rulings, and provides information on hearings. It is under the oversight of Ireland’s DPC. HAR: 32 requests, 7 domains.

Hotjar on the courts service’s site

static.hotjar.com/c/hotjar-3260934.js (+210 ms) — Hotjar, an American session-recording and heatmap service. It loads without consent, simultaneously with GTM. Hotjar records every visitor’s mouse movements, clicks, and scrolling. For a site visited by people looking into court cases, hearing lists, and registers, this represents a sensitive category of behavioral data being transmitted to the USA without consent.

The site’s own cookies-manager — does not block

courts.ie/ResourcePackages/cookies-manager/cookies-manager.js (+195 ms) — the site’s own cookie-management implementation. It loads before GTM and Hotjar (+195 ms versus +210 ms), but does not block their initialization. This is the same architectural problem seen at firmenbuch.at and auftrag.at — a CMP is present but does not stop trackers until consent is given.

The policy — current, with some nuances

The privacy policy mentions: YouTube in privacy-enhanced mode (cookies set only upon a click), and the right to access, rectify, object to, and erase data. The section on court records is clear: data from court proceedings falls under the control of the courts themselves (not the Courts Service), governed by Section 158 of the Data Protection Act 2018. Hotjar is not mentioned in the policy.

Conclusion

The Courts Service has its own cookie manager, but it does not block trackers. GTM and Hotjar load without consent. For a government body within the judicial system, running Hotjar without consent is an undesirable choice. Blocking trackers until consent is given via correct configuration of the cookies-manager, along with removing Hotjar or placing it behind the consent barrier, is the fix.

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: ie/courts-ie-2026-05-31.har
SHA-256: 6da274bebcc7e3d5e49230f08398b6e0ea311895812527a0505c9ad815acf8ba
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) — courts.ie

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 courts.ie.

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) GTM (+210 ms) and Hotjar (+210 ms) load simultaneously — 15 ms before the site's own cookies-manager.js (+195 ms). Initialization order: trackers before the CMP. The GA collect call goes out at +5351 ms, unblocked.

2) Hotjar records mouse movements, clicks, and scrolling (session recording and heatmaps). It activates without consent, simultaneously with GTM. For the website of a court service, this is a sensitive category of visitor.


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/ie-courts-ie/

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: Data Protection Commission (DPC) — dataprotection.ie

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 — courts.ie

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

2. Circumstances
I visited the website courts.ie 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) GTM (+210 ms) and Hotjar (+210 ms) load simultaneously — 15 ms before the site's own cookies-manager.js (+195 ms). Initialization order: trackers before the CMP. The GA collect call goes out at +5351 ms, unblocked.

2) Hotjar records mouse movements, clicks, and scrolling (session recording and heatmaps). It activates without consent, simultaneously with GTM. For the website of a court service, this is a sensitive category of visitor.

Full technical documentation is published at: https://gdpru.eu/en/audits/ie-courts-ie/

3. GDPR provisions I ask you to examine
GDPR Art. 6(1), Art. 5(1)(a); GDPR Art. 6(1)(a) — Hotjar

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]