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Technical audit · 31.05.2026

etenders.gov.ie

eTenders — Ireland's Government Electronic Tendering Platform
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 findings: Google Fonts and Cloudflare cdnjs, both without consent. There is no cookie banner at all.

Request timeline

+272 ms · no banner
cdnjs.cloudflare.com — gijgo 1.7.0 CSS (a date-picker UI component). The Cloudflare CDN. The sole request to Cloudflare.
+309 ms · no banner
fonts.googleapis.com — two requests: Roboto Slab (300,400,700) + Roboto (100,300,400,500,700), and Source Code Pro. The user's IP address is transmitted to Google's servers in the USA.
+328 ms · no banner
fonts.gstatic.com — a Roboto woff2 file. Google's servers, USA.
No analytics, no trackers
No Google Analytics, no GTM, no advertising pixels. No cookie banner. Set-Cookie is zero. Font Awesome is hosted locally (/epps/css/bt/font-awesome.min.css). jQuery, Bootstrap, and moment.js are all local.

Declared versus actual

+ Google Fonts (fonts.googleapis.com, fonts.gstatic.com) — not mentioned in the GDPR Statement — not declared
+ Cloudflare cdnjs (cdnjs.cloudflare.com) — not mentioned — not declared

Transfer timings

+272 ms cdnjs.cloudflare.com

gijgo 1.7.0 CSS. Cloudflare CDN.

+309 ms fonts.googleapis.com

Roboto Slab + Roboto + Source Code Pro. USA.

+328 ms fonts.gstatic.com

Roboto woff2. Google's servers. USA.

Detected trackers

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 findings — 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 findings 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.

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/etenders-gov-ie-2026-05-31.har
SHA-256: 8eb1beac3e690cdb511f1a50d3a2b78e31c14dc1f9d095091eb76c8937a3301b
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) — etenders.gov.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 etenders.gov.ie.

1. Categories of data and purposes of processing (Art. 15(1)(a)-(c))
I request information on all categories, purposes, and recipients of my data processed on this site — regardless of whether any non-compliance has been identified to date.

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-etenders-gov-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 — etenders.gov.ie

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:

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

3. GDPR provisions I ask you to examine


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]