HPRA — Ireland's regulator for medicinal products, medical devices, and veterinary medicines. 39 requests, 10 domains. GTM loads 109 ms ahead of the banner. Monotype fonts and the jQuery CDN load prior to consent. browser-update.org is an undocumented script. The policy is detailed for regulatory data and empty for web data.
Timeline of the leak
Declared versus actual
Transfer timings
jQuery Migrate 3.5.2 + jQuery UI 1.13.2. jQuery Foundation. USA.
Cludo search JS. Denmark.
GTM-WZ6M8HK3. USA.
Monotype fonts. projectid=a3cc82a1. USA.
CookiePro otBannerSdk.js. UUID 01926cc0.
Cludo API publicsettings. x2.
update.min.js. Outdated-browser script.
Detected trackers
- Google Tag Manager (www.googletagmanager.com, GTM-WZ6M8HK3)
- Cludo search engine (customer.cludo.com, api.cludo.com)
- Monotype / fast.fonts.net (fast.fonts.net)
- browser-update.org (browser-update.org)
- jQuery CDN (code.jquery.com)
- CookiePro / OneTrust (cookie-cdn.cookiepro.com, geolocation.onetrust.com)
Indicators of GDPR non-compliance
- GDPR Art. 6(1), Art. 7; ePrivacy Regulations (SI 336/2011)GTM (GTM-WZ6M8HK3) loads at +266 ms. The CookiePro banner (otBannerSdk.js) appears at +375 ms. Gap: 109 ms. Monotype fonts (fast.fonts.net) load at +271 ms without consent, transmitting the user's IP address to Monotype's servers in the USA. browser-update.org/update.min.js loads at +582 ms without consent. The jQuery CDN (code.jquery.com) fires two requests at +245 ms without consent. Cludo (+246 ms) and the Cludo API (+582 ms) fire both before and after the banner.
- GDPR Art. 6(1) — browser-update.org as an undocumented external domainbrowser-update.org is an open-source project that alerts users to outdated browsers. The update.min.js script loads on every page and transmits data about the user's browser to browser-update.org's servers (a German non-profit project, but nevertheless an external recipient of the IP address). It is not mentioned in the privacy policy.
- GDPR Art. 13(1)(e)HPRA's privacy policy describes the processing of regulatory data (medicinal products, medical devices, professional data) in detail, but contains no mention whatsoever of web technical tools: GTM, Monotype, Cludo, browser-update.org, and the jQuery CDN are not named as recipients of visitors' website data.
Context
HPRA (the Health Products Regulatory Authority) is Ireland’s regulator for medicinal products, medical devices, veterinary medicines, and cosmetics. It participates in the European network of medicines regulators (the HMA). Sensitivity: high — visitors to the site may include healthcare professionals, patients, or individuals reporting adverse drug reactions. HAR: 39 requests, 10 domains.
GTM 109 ms ahead of the banner
GTM-WZ6M8HK3 loads at +266 ms. The CookiePro banner loads at +375 ms. The pattern is identical to that at tcd.ie, oireachtas.ie, and other sites in the series: a CMP is present, but GTM initializes before the banner has finished rendering. What the GTM container activates within these 109 ms cannot be determined from the HAR without auditing the container’s contents, but the window exists.
Monotype — a corporate font service
fast.fonts.net is the Monotype Fonts platform, a corporate alternative to Google Fonts. Unlike Google Fonts, Monotype is a paid subscription service used primarily by organizations with corporate licenses. Every request to fast.fonts.net/t/1.css?apiType=css&projectid=a3cc82a1-363c-45d7-bdf2-43868f698a3a transmits the visitor’s IP address to Monotype’s American servers. It loads at +271 ms — prior to consent, with no mention in the policy.
browser-update.org — a low-risk but undocumented script
browser-update.org/update.min.js is an open-source tool that alerts users to outdated browsers. The project is non-commercial and of German origin, with no explicit advertising or tracking function. Nevertheless, every request transmits the IP address and user agent to an external server. The script returns a 304 (Not Modified) status, indicating a cached version is present — meaning the visitor’s browser has contacted this server before. It is not mentioned in the privacy policy.
The jQuery CDN — a fixable dependency
jQuery Migrate 3.5.2 and jQuery UI 1.13.2 load from code.jquery.com (+245 ms). A local copy of jQuery 3.7.1 is already hosted at www.hpra.ie/ResourcePackages/HPRA/assets/dist/hpra/css/jquery.min.js. Individual jQuery plugins (Migrate, UI) load from an external CDN, while the core library is hosted locally. This is an inconsistent setup: moving jQuery Migrate and UI to local hosting is a trivial task.
The policy: detailed for regulatory data, empty for the web
The privacy policy describes the processing of data in a regulatory context in detail and correctly: legal bases under Art. 6(1)(a)(c)(e), special categories under Art. 9(1)(i), data sharing with European regulatory partners, and retention. There is not a single word about web technical tools. GTM, Monotype, Cludo, browser-update.org, and the jQuery CDN are all unmentioned.
Set-Cookie — zero
None of the 39 requests sets a cookie via Set-Cookie.
Conclusion
hpra.ie reproduces the standard pattern seen throughout the Irish series: a CMP is present, and GTM outpaces the banner. What sets it apart is an unusual set of external dependencies: Monotype instead of Google Fonts, browser-update.org, and Cludo. None of these tools is documented in a policy focused exclusively on regulatory data. For a body regulating products that affect citizens’ health, complete documentation of website visitor data is no less important than the accuracy of its regulatory records.
09f01c7a7bff94416475dd809875a223682f0ff8b9668d228c5470b375284fdaWhere 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 hpra.ie. 2. Circumstances I visited the website hpra.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) GTM (GTM-WZ6M8HK3) loads at +266 ms. The CookiePro banner (otBannerSdk.js) appears at +375 ms. Gap: 109 ms. Monotype fonts (fast.fonts.net) load at +271 ms without consent, transmitting the user's IP address to Monotype's servers in the USA. browser-update.org/update.min.js loads at +582 ms without consent. The jQuery CDN (code.jquery.com) fires two requests at +245 ms without consent. Cludo (+246 ms) and the Cludo API (+582 ms) fire both before and after the banner. 2) browser-update.org is an open-source project that alerts users to outdated browsers. The update.min.js script loads on every page and transmits data about the user's browser to browser-update.org's servers (a German non-profit project, but nevertheless an external recipient of the IP address). It is not mentioned in the privacy policy. 3) HPRA's privacy policy describes the processing of regulatory data (medicinal products, medical devices, professional data) in detail, but contains no mention whatsoever of web technical tools: GTM, Monotype, Cludo, browser-update.org, and the jQuery CDN are not named as recipients of visitors' website data. Full technical documentation is published at: https://gdpru.eu/en/audits/ie-hpra-ie/ 3. Provisions violated GDPR Art. 6(1), Art. 7; ePrivacy Regulations (SI 336/2011); GDPR Art. 6(1) — browser-update.org as an undocumented external domain; 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]