dublincity.ie
The municipal government of Ireland's capital. 47 requests, 5 domains. Cookiebot correctly blocks trackers until consent is given — no Google, no Matomo in the HAR. But the privacy policy describes Matomo, which is no longer in use, and says nothing about Cookiebot, which is. Three external domains go unmentioned.
Timeline of the leak
Declared versus actual
Transfer timings
Cookiebot SDK uc.js. Denmark/EU.
js-cookie v3.0.5. An open-source CDN.
CSP reporting. POST. Enovation IE.
Cookiebot configuration. UUID 1a8c2f02.
Cookiebot cc.js — the banner is rendered.
Detected trackers
- Cookiebot CMP (consent.cookiebot.com, consentcdn.cookiebot.com)
- Enovation CSP reporting (dcc-cspreport.enovation.ie)
- jsDelivr CDN (cdn.jsdelivr.net)
Indicators of GDPR non-compliance
- GDPR Art. 13(1)(e)The privacy policy declares the use of Matomo Analytics. Matomo is entirely absent from the HAR. Cookiebot, dcc-cspreport.enovation.ie, and cdn.jsdelivr.net load on every session — none of the three is mentioned in the policy. The actual set of external dependencies does not match what the policy declares.
- GDPR Art. 5(1)(a) — transparencyThe policy was last updated on 20 April 2023 and describes an architecture that does not match the site's current implementation: Matomo is declared but not in use; Cookiebot, the consent platform, is not mentioned.
Context
Dublin City Council is the local authority for Ireland’s capital, providing municipal services to over a million residents. HAR: 47 requests, 5 domains. Of these, 35 requests go to the first-party domain www.dublincity.ie, with the remaining 12 going to four external domains.
What works correctly
Cookiebot, with UUID 1a8c2f02-9b85-438c-8717-4a7f5f3afae6, correctly performs its blocking function until consent is given. The HAR records no Google Analytics, no GTM, no Matomo, and no advertising pixels — none of the issues that typically constitute violations at government sites in the Irish series. Set-Cookie is zero. The consent architecture functions as intended: trackers are blocked until the user makes a choice.
A 2023 policy and a 2026 architecture
The privacy policy was last updated on 20 April 2023. It documents the use of Matomo Analytics, an open-source web-analytics tool. In the HAR from May 2026, Matomo is entirely absent: there is not a single request to matomo.cloud, matomo.php, or comparable endpoints.
At the same time, the policy makes no mention of Cookiebot — the consent management platform that actually runs on the site, establishing connections to consent.cookiebot.com and consentcdn.cookiebot.com on every session. Cookiebot is a Danish company belonging to the Usercentrics group; its platform processes user consent data, including IP addresses and device identifiers.
The result: the system documented in the policy (Matomo) is not in use, and the system actually in use (Cookiebot) is undocumented.
CSP reporting via enovation.ie
Six POST requests to dcc-cspreport.enovation.ie/csp-report-dccdrupal.php implement Content Security Policy reporting: the browser sends reports of CSP violations on the site to an external endpoint. Enovation is an Irish company that develops and maintains Dublin City Council’s Drupal platform. CSP reports contain technical data about the browser and the violated directives, but not identifying personal data about the user in the standard sense. Nevertheless, as an external processor, Enovation is mentioned in the privacy policy neither as a recipient nor as a data processor.
Conclusion
dublincity.ie presents a picture rare in the Irish series: the consent mechanism actually works, and trackers do not launch prior to consent. There is one violation, but it is telling: the privacy policy describes tools that are no longer in use and says nothing about the tools that actually are. For a municipality with obligations to a million residents, documentation accuracy is not a formality. The fix is technical: update the policy, removing Matomo and adding Cookiebot and Enovation to the list of data processors.
0a2c1125687df2143176749a1c49e84f5c966c15d497425661e86389e340fe2bWhere to file: Data Protection Commission (DPC) — dataprotection.ie
To: Data Protection Commission (DPC) 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 dublincity.ie. 2. Circumstances I visited the website dublincity.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) The privacy policy declares the use of Matomo Analytics. Matomo is entirely absent from the HAR. Cookiebot, dcc-cspreport.enovation.ie, and cdn.jsdelivr.net load on every session — none of the three is mentioned in the policy. The actual set of external dependencies does not match what the policy declares. 2) The policy was last updated on 20 April 2023 and describes an architecture that does not match the site's current implementation: Matomo is declared but not in use; Cookiebot, the consent platform, is not mentioned. Full technical documentation is published at: https://gdpru.eu/en/audits/ie-dublincity-ie/ 3. Provisions violated GDPR Art. 13(1)(e); GDPR Art. 5(1)(a) — transparency 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]