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Technical audit · 31.05.2026

dublincity.ie

Dublin City Council — the municipal government of Ireland's capital
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.

Request timeline

+56 ms · before the banner
consent.cookiebot.com/uc.js — the Cookiebot SDK loads. The first and only external tracking-related domain to load before the banner.
+75–182 ms · before the banner
dcc-cspreport.enovation.ie/csp-report-dccdrupal.php — six CSP-reporting POST requests. Enovation is an Irish developer serving Dublin City Council. CSP reports contain technical browser data, but not personal data about the user in the ordinary sense.
+59 ms · before the banner
cdn.jsdelivr.net — the js-cookie library. A single request.
+109–112 ms · banner
consentcdn.cookiebot.com — banner configuration (configuration.js, settings.json, bc-v4.min.html, cc.js). Cookiebot UUID: 1a8c2f02-9b85-438c-8717-4a7f5f3afae6.
Blocking prior to consent
Neither Google Analytics, Matomo, GTM, nor advertising pixels are recorded in the HAR. Set-Cookie is zero. Cookiebot performs its blocking function correctly.

Declared versus actual

✓ Matomo Analytics — mentioned in the privacy policy (2023) — declared
+ Cookiebot (consent.cookiebot.com, consentcdn.cookiebot.com) — not mentioned — not declared
+ Enovation CSP reporting (dcc-cspreport.enovation.ie) — not mentioned — not declared
+ jsDelivr (cdn.jsdelivr.net) — not mentioned — not declared

Transfer timings

+56 ms consent.cookiebot.com

Cookiebot SDK uc.js. Denmark/EU.

+59 ms cdn.jsdelivr.net

js-cookie v3.0.5. An open-source CDN.

+75 ms dcc-cspreport.enovation.ie

CSP reporting. POST. Enovation IE.

+109 ms consentcdn.cookiebot.com

Cookiebot configuration. UUID 1a8c2f02.

+112 ms consent.cookiebot.com

Cookiebot cc.js — the banner is rendered.

Detected trackers

Indicators of GDPR non-compliance

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 finding, 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.

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/dublincity-ie-2026-05-31.har
SHA-256: 0a2c1125687df2143176749a1c49e84f5c966c15d497425661e86389e340fe2b
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) — dublincity.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 dublincity.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) 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.


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-dublincity-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 — dublincity.ie

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. GDPR provisions I ask you to examine
GDPR Art. 13(1)(e); GDPR Art. 5(1)(a) — transparency

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]