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Technical audit · 31.05.2026

gov.ie

gov.ie — Official Portal of the Government of Ireland
IE

Policy changed — see what exactly · 2026-08-26 →

gov.ie — the main portal of the Irish government. 15 requests, 3 domains — all Irish. No Google, no GTM, no advertising networks. Fonts, icons, and CSS are all local, served from assets.gov.ie. The sole external tracker is a government-run Matomo instance. It activates without a consent banner.

Request timeline

+49 ms · load
assets.gov.ie — all resources: Lato woff2 (400, 700), Material Symbols woff2, design-system CSS, JS modules. All local.
+76 ms · no banner
track.analytics.services.gov.ie/tr4ck3rj — the Matomo JS loads. A government-run domain, analytics.services.gov.ie.
+123 ms · no banner
track.analytics.services.gov.ie/tr4ck3rp — a Matomo tracking request: idsite=1, action_name=Government of Ireland: Welcome to gov.ie, the full URL. No cookie banner is present.

Declared versus actual

✓ Matomo Analytics — documented in detail, with a description of its cookieless mode — declared
✓ The risk of PII capture via the search bar — explicitly warned about in the policy — declared

Transfer timings

+76 ms track.analytics.services.gov.ie

Matomo JS tr4ck3rj. A government-run domain. idsite=1.

+123 ms track.analytics.services.gov.ie

Matomo PHP tr4ck3rp. Tracking request. Cookieless.

Detected trackers

Indicators of GDPR non-compliance

Context

gov.ie is the central information portal of the Government of Ireland, run by the Department of Public Expenditure, Infrastructure, Public Service Reform and Digitalisation. HAR: 15 requests, 3 domains. 12 requests go to assets.gov.ie (the government’s CDN for static resources), 1 to www.gov.ie, and 2 to track.analytics.services.gov.ie.

Architectural discipline

gov.ie demonstrates a government architecture built with privacy requirements in mind: the Lato and Material Symbols fonts are hosted on assets.gov.ie, not on Google Fonts. Design-system CSS, all JS modules, and icons are hosted locally. There is no Google Tag Manager, no Google Analytics, no Facebook, and no third-party library CDN. The sole external connection is a government-run Matomo instance on the domain analytics.services.gov.ie.

Matomo without a banner — a systemic choice

The privacy policy describes Matomo honestly and in detail: cookieless tracking, no PII in standard requests, IP anonymization. This is considerably better than most sites in the Irish series, where analytics goes unmentioned entirely. But Matomo launches on the very first page load — there is no banner, no opt-in mechanism, and no way to decline before tracking begins.

This is the same model seen at revenue.ie and the OGCIO: government infrastructure, a cookieless mode, conscientious documentation — but activation prior to consent. Cookieless tracking does not exempt a site from the requirements of the ePrivacy Regulations: the directive and its Irish implementation (SI 336/2011) apply to any access to, or storage of information on, a user’s terminal equipment, regardless of whether cookies are used.

One paragraph of the policy deserves particular attention: Matomo “may capture and store any PII entered using the search feature on gov.ie. This can occur if users include names, email addresses, or other personal data in their search queries. We advise users not to enter personal or sensitive information into the search bar.” This is a rare case of a government body honestly warning about a specific risk of personal-data capture via an analytics tool. This kind of transparency is worth noting. At the same time, it makes the absence of an opt-in mechanism more conspicuous: the user is warned of the risk but has no technical means of protecting themselves from it.

Set-Cookie — zero

None of the 15 requests sets a cookie via Set-Cookie. Matomo operates in a fully cookieless mode — consistent with the declared policy.

Conclusion

gov.ie, the country’s main government portal, embodies a state approach to privacy architecture: local resources, self-hosted analytics infrastructure, and an honest and detailed policy. The sole finding — the absence of an opt-in mechanism for Matomo — is procedural in nature and reflects a systemic choice made across the entire gov.ie platform. Of all the Irish government sites reviewed in this series, gov.ie comes closest to a correct architecture: one step remains — adding a consent banner ahead of the Matomo request.

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/gov-ie-2026-05-31.har
SHA-256: 617f9e13b7eda3cc02fe6ab131229fc4d8d5b37fc7783d2b3917c981b4c15387
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) — 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 gov.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) track.analytics.services.gov.ie/tr4ck3rj loads at +76 ms and sends a tracking request to /tr4ck3rp at +123 ms — on the very first page load, with no consent banner and no user interaction whatsoever. The policy declares cookieless tracking with no PII. Nevertheless, the mere fact that visit data (IP address, user agent, URL, timestamps) is transmitted to an external server occurs prior to consent. The ePrivacy Regulations apply not only to cookies but to any access to, or storage of information on, a user's terminal equipment.

2) The policy warns that Matomo 'may capture and store any PII entered using the search feature on gov.ie. This can occur if users include names, email addresses, or other personal data in their search queries.' This is honest risk disclosure, rare among the sites reviewed in this series. However, the presence of this risk in the absence of a banner or opt-in mechanism compounds the violation: the user cannot opt out of analytics before interacting with the site.


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-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 — gov.ie

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

2. Circumstances
I visited the website 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) track.analytics.services.gov.ie/tr4ck3rj loads at +76 ms and sends a tracking request to /tr4ck3rp at +123 ms — on the very first page load, with no consent banner and no user interaction whatsoever. The policy declares cookieless tracking with no PII. Nevertheless, the mere fact that visit data (IP address, user agent, URL, timestamps) is transmitted to an external server occurs prior to consent. The ePrivacy Regulations apply not only to cookies but to any access to, or storage of information on, a user's terminal equipment.

2) The policy warns that Matomo 'may capture and store any PII entered using the search feature on gov.ie. This can occur if users include names, email addresses, or other personal data in their search queries.' This is honest risk disclosure, rare among the sites reviewed in this series. However, the presence of this risk in the absence of a banner or opt-in mechanism compounds the violation: the user cannot opt out of analytics before interacting with the site.

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

3. GDPR provisions I ask you to examine
GDPR Art. 7; ePrivacy Regulations (SI 336/2011) — cookieless tracking without consent; 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]