etenders.gov.ie
Ireland's government tendering platform — processes PPSN (Ireland's equivalent of a national tax ID), financial data, and organizations' tender documentation. 44 requests, 4 domains. No analytics, no GTM. The sole violations: Google Fonts and Cloudflare cdnjs, both without consent. There is no cookie banner at all.
Timeline of the leak
Declared versus actual
Transfer timings
gijgo 1.7.0 CSS. Cloudflare CDN.
Roboto Slab + Roboto + Source Code Pro. USA.
Roboto woff2. Google's servers. USA.
Detected trackers
- Google Fonts (fonts.googleapis.com, fonts.gstatic.com)
- Cloudflare cdnjs (cdnjs.cloudflare.com)
Indicators of GDPR non-compliance
- GDPR Art. 6(1); ePrivacy Regulations (SI 336/2011)Google Fonts (fonts.googleapis.com) loads at +309 ms without consent: two font families (Roboto Slab + Roboto, Source Code Pro). fonts.gstatic.com loads a woff2 file at +328 ms. The user's IP address is transmitted to Google's servers in the USA. There is no cookie banner and no consent mechanism.
- GDPR Art. 13(1)(e)The GDPR Statement (May 2023) describes only registration and tendering data. Google Fonts and Cloudflare cdnjs, as recipients of visitors' technical data, are not mentioned. The site has no cookie-consent mechanism whatsoever.
Context
eTenders (www.etenders.gov.ie) is Ireland’s official electronic tendering platform, administered by the Office of Government Procurement (OGP). Through the platform, all government bodies publish tender notices, and suppliers submit bids and tender documentation. Registration collects name, address, phone number, email, and, in certain cases, PPSN (Personal Public Services Number — Ireland’s equivalent of a national tax ID). Sensitivity: high. HAR: 44 requests, 4 domains.
The cleanest architecture in the series
etenders.gov.ie demonstrates an architectural approach rare among Irish government sites: no Google Analytics, no Google Tag Manager, no advertising pixels, no Hotjar, no Clarity, no social media aggregators. Font Awesome 4.7.0 is hosted locally (/epps/css/bt/font-awesome.min.css, /epps/fonts/bt/fontawesome-webfont.woff2). jQuery 1.11.3, Bootstrap, moment.js, and htmx are all hosted on the first-party domain. Of 44 requests, 40 go to www.etenders.gov.ie.
The platform is developed and hosted by European Dynamics, a Greek IT provider with a data center in Athens. The GDPR Statement states directly that data is not transferred outside the EEA.
Two violations — minimal in scale
The only external domains are Google Fonts (two requests to fonts.googleapis.com, one to fonts.gstatic.com) and Cloudflare cdnjs (one request — gijgo 1.7.0 CSS, a date-picker UI component). Both transmit the visitor’s IP address to external servers without consent and without a cookie banner. There is no consent mechanism at all: no OneTrust, no Cookiebot, no custom-built banner.
Technically, both violations can be fixed in a single step: host Roboto Slab, Roboto, and Source Code Pro locally (as has already been done for Font Awesome), and replace the Cloudflare cdnjs call with a locally hosted copy of gijgo. This is the same task the European Dynamics team has already completed for every other library on the site.
The GDPR Statement — registration data without the technical side
The GDPR Statement (May 2023) describes the processing of registration and tender data in detail: legal bases, joint controllers, data subject rights, and retention procedures. This is a substantive document for a platform processing business data. It is entirely silent on the technical side, however — every unregistered visitor browsing tender notices transmits their IP address to Google and Cloudflare, and this is nowhere documented.
Set-Cookie — zero
None of the 44 requests sets a cookie via Set-Cookie. Cookies are also absent from outgoing requests.
Conclusion
etenders.gov.ie is the strongest example of minimalism in the Irish series: two external domains, neither a tracker, no analytics, no GTM, and every library hosted locally. Violations do exist, but they are technical in nature: three requests to Google and one to Cloudflare can be replaced with local hosting in a day’s work. For a government platform processing financial data and PPSNs, this architectural discipline is exemplary.
8eb1beac3e690cdb511f1a50d3a2b78e31c14dc1f9d095091eb76c8937a3301bWhere 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 etenders.gov.ie. 2. Circumstances I visited the website etenders.gov.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) Google Fonts (fonts.googleapis.com) loads at +309 ms without consent: two font families (Roboto Slab + Roboto, Source Code Pro). fonts.gstatic.com loads a woff2 file at +328 ms. The user's IP address is transmitted to Google's servers in the USA. There is no cookie banner and no consent mechanism. 2) The GDPR Statement (May 2023) describes only registration and tendering data. Google Fonts and Cloudflare cdnjs, as recipients of visitors' technical data, are not mentioned. The site has no cookie-consent mechanism whatsoever. Full technical documentation is published at: https://gdpru.eu/en/audits/ie-etenders-gov-ie/ 3. Provisions violated GDPR Art. 6(1); ePrivacy Regulations (SI 336/2011); GDPR Art. 13(1)(e) 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]